A battery label and a battery passport are often confused because both give information about the same battery, and because the label carries the QR code that gives access to the passport. The label is the information marked on the battery itself, under Article 13 of Regulation (EU) 2023/1542, including the crossed out wheeled bin symbol, capacity information, chemistry and other marking elements set out in Article 13 and Annex VI. The passport is the electronic record behind the data carrier, under Article 77 and Annex XIII, containing model and individual information, including information resulting from use. A reader who treats the label as the passport will miss the history, and a reader who treats the passport as the label will miss the immediate facts that the battery itself must carry.
The scope is the distinction between labelling and passport duties, as checked on 28 October 2026. The guide does not state the full marking specification for any category, and a reader should check Article 13 and Annex VI for the category in question.
What information does the label carry?
The label carries the information that Article 13 requires to be marked on the battery, in a form that can be read at the battery without a device, including the separate collection symbol, capacity, chemistry and, where relevant, hazardous substance and carbon footprint information, with the precise elements varying by category and by date. The label is designed for immediate identification and handling, and it must remain legible and durable for the life of the battery. A label that is damaged, obscured or removed leaves a later handler without the immediate facts, even where the passport behind the carrier remains intact, and the handling decision should pause until the label information is recovered from the record or the documents.
What information does the passport carry?
The passport carries the full structured record, with model information and individual information split by access tier, including manufacturer and model facts, composition, performance and durability, carbon footprint, recycled content, due diligence, safety measures, dismantling information and later use information, as Annex XIII sets out. The passport is designed for a dated history, not for immediate reading at the battery, and it requires a device to scan the carrier and a system to show the record. A passport that is complete but cannot be reached because the carrier is damaged is a record without access, and a label that is complete but has no passport behind it, where a passport is required, is an immediate fact without a history. Both are needed where both duties apply.
How do label and passport dates differ?
Label and passport dates differ because labelling duties phase in under Article 13 on their own timetable, with the general label from August 2026 in the summaries and the QR code from 18 February 2027, while the passport duty applies from 18 February 2027 under Article 77. A battery can therefore carry a label before it carries a passport, and a battery placed before the passport date can carry a label and a QR code giving access to Article 13 information without carrying a passport. The date distinction matters for used batteries, because a battery placed before 18 February 2027 may have a label and a QR code but no passport duty, and a buyer who expects a passport for such a battery applies the wrong date test. The placing date decides both duties, and it should be recorded.
What does a label and passport table look like?
A label and passport table keeps the place, the content and the access route apart for each. The table below states the positions in general terms.
| Feature | Label | Passport |
|---|---|---|
| Place | Marked on battery | Electronic record behind carrier |
| Content | Immediate facts, Article 13 | Full history, Annex XIII |
| Access | Read at battery, no device | Scan carrier, device and system |
| Duty date | Phased under Article 13 | 18 February 2027, Article 77 |
What happens when label and passport disagree?
When label and passport disagree, whether in capacity, chemistry, category or identifier, the disagreement should be recorded and resolved before the battery is handled or sold on the basis of either source, because handling or selling on a mistaken source carries a safety and a commercial risk. Possible causes include a labelling error, a record error, a replacement battery with the wrong label, or a record that has not been updated after a change, and each cause needs a different remedy. The disagreement should be investigated by comparing the label, the record, the specification and the documents, with the findings recorded, rather than by choosing the source that is more convenient. A resolved disagreement, recorded with the remedy, strengthens the file.
How should a reader use both together?
A reader should use both together by starting with the label for immediate identification, then scanning the carrier to reach the passport for history, then comparing the two, and then recording the comparison with dates. The label answers what battery is in hand, the passport answers what that battery has done and what is recorded about it, and the comparison answers whether the two agree. A reading that uses only the label, or only the passport, is a partial reading, and a purchase, handling or collection decision that rests on a partial reading is weaker than a decision that rests on both. The combined reading, recorded with dates, is the file that a later reader needs.
What limits apply to this distinction?
The limits are that marking specifications turn on category and date, and this guide states them only in general terms. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery should check Article 13, Annex VI and Article 77 as checked on 28 October 2026 before acting.
Sources & further reading
- Regulation (EU) 2023/1542 EUR-Lex summary ↗
- Regulation (EU) 2023/1542 consolidated text as at 18 July 2024 on EUR-Lex ↗
- IEC 62660-3 safety requirements for lithium ion cells ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.