Checking labels against the record is a line by line comparison of the physical marking on a battery, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the underlying test and composition data. The check is not a visual glance at the label; it is a documented comparison in which each label element is matched to a source, and each match is recorded as a pass, a fail, or a query. The check record must state the battery identifier or model, the label artwork version, the document versions compared, the checker, and the date. A check that records only a general pass gives a later reviewer no way to know what was compared. The method should be the same for every model, so results can be compared across a range.
A label check means the systematic comparison of marking content with the authoritative records behind the marking. The scope covers all label elements, the QR code, the passport entry, and the declaration, for the battery or model stated.
What is the legal frame for this marking?
Checking labels against the record is a physical marking duty and a record duty at the same time. A quality checker comparing a finished pack label with its passport entry should work from the current consolidated text and check whether an implementing act on harmonised label specifications has entered into force, since Article 13 sets some dates by reference to that act. A checker for an EV pack should compare the capacity, chemistry, manufacturer, and identifier on the label with the passport entry and the test record, scan the QR code, and record each line before the pack is released.
How are content, placement, and legibility checked?
Content asks whether every required element for checking labels against the record is present and correct for the battery category. The check sheet, scan test log, and query log should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Sampling must be stated where not every battery is checked, including the sample size, the selection method, and the reason for sampling, so a sampled check is not presented as a check of every battery.
How does category decide content?
Category decides content. For checking labels against the record, the record should state the category as defined in Article 3, list the label elements that apply to that category, and list the elements that do not apply, with the reason. A quality checker comparing a finished pack label with its passport entry should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A checker for an EV pack should compare the capacity, chemistry, manufacturer, and identifier on the label with the passport entry and the test record, scan the QR code, and record each line before the pack is released.
How are measurement and wording recorded?
For checking labels against the record, a capacity value, a chemistry statement, or a duration value should name the test method, the conditions, and the unit, so the same battery tested again gives a comparable result. The check sheet, scan test log, and query log should include the test report or the calculation sheet, the date, and the person or function that approved the value. Sampling must be stated where not every battery is checked, including the sample size, the selection method, and the reason for sampling, so a sampled check is not presented as a check of every battery.
What sits behind the marking in the documentation?
For checking labels against the record, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A quality checker comparing a finished pack label with its passport entry should check that the declaration date, the battery model, and the marking version are consistent, and that a change to the battery that affects conformity leads to a review of the documentation. A checker for an EV pack should compare the capacity, chemistry, manufacturer, and identifier on the label with the passport entry and the test record, scan the QR code, and record each line before the pack is released.
How is a marking checked line by line?
For checking labels against the record, a checker should compare the physical marking, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the technical documentation, line by line, and record each comparison with a pass, a fail, or a query. The check sheet, scan test log, and query log for the check should include the date, the sample identifier, and the version of each document compared. A quality checker comparing a finished pack label with its passport entry should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Sampling must be stated where not every battery is checked, including the sample size, the selection method, and the reason for sampling, so a sampled check is not presented as a check of every battery.
How is a check sheet completed for one battery?
A check sheet for one battery lists every label element in one column, the source record in the next, and the result in the third. The checker works down the sheet: label value, source value, match or difference, with the document version for each source. A worked sheet for an EV pack shows capacity, chemistry, manufacturer, identifier, QR destination, and declaration, each with a source and a result. Queries are written in a separate query log, with an owner and a decision date, and the battery is not released until every query is resolved or owned by a named decision. The completed sheet, with the scan test log, is filed by identifier, so the check for one battery can be retrieved without searching a batch file.
| Comparison | Source A | Source B |
|---|---|---|
| Label value | Physical label | Test or composition record |
| QR destination | Scanned code | Passport or information page |
| Declaration | Declaration text | Marking and technical documentation |
A check closes only when every query is resolved or owned, and an open query at release is a decision that the record should show, with the decision maker named.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, EUR-Lex ↗
- Batteries, European Commission ↗
- Critical and Strategic Materials, Joint Research Centre Raw Materials Information System ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.