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Labelling for different battery categories

Labelling differs by battery category, and the record must list the elements that apply to each category and the reason for each element that does not apply.

GUIDE / EU REGULATIONIDENTITY → INFORMATION → EVIDENCE

Labelling differs by battery category, and a single label design cannot be applied to every battery without checking which elements apply to each category. Portable batteries, LMT batteries, SLI batteries, EV batteries, and industrial batteries share several elements, such as the separate collection symbol and the general information label, but differ on capacity labelling, duration labelling, carbon footprint labelling, and passport related QR destinations. The record for a product range should hold a category matrix that lists each category, each label element, whether the element applies, and the article basis. A matrix that is built once and never reviewed will drift as battery models change category or as delegated acts add label elements.

Battery categories, in this record, are the five categories defined in Article 3: portable, LMT, SLI, EV, and industrial batteries. The scope is the label elements in Article 13 and Annex VI, plus carbon footprint labelling where Article 7 applies.

Labelling for different battery categories is a physical marking duty and a record duty at the same time. A product manager maintaining a label matrix across portable and industrial ranges 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 range that includes portable rechargeable cells and industrial packs should show capacity labelling for the portable cells, and a passport QR destination for the industrial packs, with the matrix stating the basis for each difference.

How are content, placement, and legibility checked?

Content asks whether every required element for labelling for different battery categories is present and correct for the battery category. The category matrix, category decisions, and artwork versions should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Carbon footprint labelling under Article 7 follows a separate timetable by category, with performance classes dependent on delegated and implementing acts, and the matrix should mark carbon footprint label elements as expected until those acts are in force.

How does category decide content?

Category decides content. For labelling for different battery categories, 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 product manager maintaining a label matrix across portable and industrial ranges should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A range that includes portable rechargeable cells and industrial packs should show capacity labelling for the portable cells, and a passport QR destination for the industrial packs, with the matrix stating the basis for each difference.

How are measurement and wording recorded?

For labelling for different battery categories, 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 category matrix, category decisions, and artwork versions should include the test report or the calculation sheet, the date, and the person or function that approved the value. Carbon footprint labelling under Article 7 follows a separate timetable by category, with performance classes dependent on delegated and implementing acts, and the matrix should mark carbon footprint label elements as expected until those acts are in force.

What sits behind the marking in the documentation?

For labelling for different battery categories, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A product manager maintaining a label matrix across portable and industrial ranges 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 range that includes portable rechargeable cells and industrial packs should show capacity labelling for the portable cells, and a passport QR destination for the industrial packs, with the matrix stating the basis for each difference.

How is a marking checked line by line?

For labelling for different battery categories, 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 category matrix, category decisions, and artwork versions for the check should include the date, the sample identifier, and the version of each document compared. A product manager maintaining a label matrix across portable and industrial ranges should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Carbon footprint labelling under Article 7 follows a separate timetable by category, with performance classes dependent on delegated and implementing acts, and the matrix should mark carbon footprint label elements as expected until those acts are in force.

How is a category matrix used for a new model?

Using a matrix for a new model starts with the category decision, recorded with the Article 3 definition and the facts relied on. The matrix row for that category is then read across: general information, capacity, duration, collection symbol, chemical symbols, carbon footprint, and QR destination, each marked as applies or does not apply, with the article basis. A worked matrix entry for a new LMT model shows capacity labelling as applies, passport QR as applies from 18 February 2027, and duration labelling as does not apply, with reasons. The artwork is then built from the matrix row, and the checker signs the matrix entry. A model built from another category row, without a new matrix entry, inherits the wrong label set.

CategoryCapacity labelPassport QR
Portable rechargeableYes, Article 13(2)No, general QR destination
LMTYes, Article 13(2)Yes, from 18 February 2027
Industrial over 2 kWhNot under Article 13(2) as statedYes, from 18 February 2027

A matrix is useful only while it is reviewed, and a category decision that is not recorded will be remade differently by the next person who checks the range.

Sources & further reading

Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.

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