Labelling requirements

Labelling requirements under Article 13 of Regulation (EU) 2023/1542 set out what must appear on a battery, in what form, and from what date. The general information label in Annex VI Part A, the capacity label for specified rechargeable batteries, the duration and non rechargeable label for non rechargeable portable batteries, the separate collection symbol, and the chemical symbols for cadmium and lead each have their own scope and date. The general information and capacity labels apply from 18 August 2026 or 18 months after the implementing act on harmonised specifications enters into force, whichever is later. The separate collection symbol applies from 18 August 2025. A single checklist that gives one date for all labels will misstate the duty.

Labelling means the labels and markings that a battery must bear under Article 13 and Annex VI. The scope covers all battery categories, with specified elements applying only to specified categories, as set out in the article.

What is the legal frame for this marking?

Labelling requirements under Article 13 is a physical marking duty and a record duty at the same time. A label designer preparing artwork for a rechargeable portable battery 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 rechargeable portable battery label should carry general information and capacity information, plus the separate collection symbol, with each element checked against Annex VI Part A and Part B for that category.

How are content, placement, and legibility checked?

Content asks whether every required element for labelling requirements under Article 13 is present and correct for the battery category. The artwork, Annex VI checklist, and approval record should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Annex VI Part A lists manufacturer identity, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, and critical raw materials above thresholds, and the artwork check should follow that list in order.

How does category decide content?

Category decides content. For labelling requirements under Article 13, 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 label designer preparing artwork for a rechargeable portable battery should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A rechargeable portable battery label should carry general information and capacity information, plus the separate collection symbol, with each element checked against Annex VI Part A and Part B for that category.

How are measurement and wording recorded?

For labelling requirements under Article 13, 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 artwork, Annex VI checklist, and approval record should include the test report or the calculation sheet, the date, and the person or function that approved the value. Annex VI Part A lists manufacturer identity, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, and critical raw materials above thresholds, and the artwork check should follow that list in order.

What sits behind the marking in the documentation?

For labelling requirements under Article 13, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A label designer preparing artwork for a rechargeable portable battery 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 rechargeable portable battery label should carry general information and capacity information, plus the separate collection symbol, with each element checked against Annex VI Part A and Part B for that category.

How is a marking checked line by line?

For labelling requirements under Article 13, 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 artwork, Annex VI checklist, and approval record for the check should include the date, the sample identifier, and the version of each document compared. A label designer preparing artwork for a rechargeable portable battery should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Annex VI Part A lists manufacturer identity, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, and critical raw materials above thresholds, and the artwork check should follow that list in order.

How is a label artwork checked line by line?

An artwork check follows Annex VI Part A in order, line by line. The checker reads the manufacturer name, the category, the place and date of manufacture, the weight, the capacity, the chemistry, the hazardous substances, and the critical raw materials, and ticks each line against the composition and test records. The separate collection symbol is checked for size and placement, and the capacity label is checked against the test report. A worked check sheet for one artwork version shows each line, the source record, and the result, with the checker and date. An artwork that passes every line except one is not passed; the failed line is corrected, the artwork version is raised, and the check is repeated for the corrected line and for any line affected by the correction.

A label is complete only when every element for its category is present, and an element for another category does not compensate for a missing element for this one.