Marking durability means the labels and QR codes on a battery remain visible, legible, and indelible through the conditions of use, storage, and handling that the battery will meet. Article 13(7) requires labels and the QR code to be printed or engraved visibly, legibly, and indelibly on the battery, or, where that is not possible or not warranted by the nature and size of the battery, on the packaging and the accompanying documents. Durability is not a claim about a label material in general; it is a result for a marking method on a battery surface, under temperature, abrasion, moisture, and chemical exposure relevant to the application. The record must state the marking method, the test or trial applied, and the result, with the date.
Marking durability means the continued legibility and adhesion of a label or engraving under expected conditions of use. The scope covers the label and QR code for the battery model and surface stated, for the conditions stated.
What is the legal frame for this marking?
Marking durability is a physical marking duty and a record duty at the same time. A production engineer trialling label materials on a battery enclosure 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 label on an industrial battery stored outdoors should be trialled under temperature cycling, moisture, and abrasion, and the trial should include a QR scan test after exposure, not only a visual check.
How are content, placement, and legibility checked?
Content asks whether every required element for marking durability is present and correct for the battery category. The durability trial record, material specification, and sample retention should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. The Regulation sets no durability period in years, so the record should state the conditions tested and the result, rather than claim a period of durability that no test supports.
How does category decide content?
Category decides content. For marking durability, 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 production engineer trialling label materials on a battery enclosure should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A label on an industrial battery stored outdoors should be trialled under temperature cycling, moisture, and abrasion, and the trial should include a QR scan test after exposure, not only a visual check.
How are measurement and wording recorded?
For marking durability, 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 durability trial record, material specification, and sample retention should include the test report or the calculation sheet, the date, and the person or function that approved the value. The Regulation sets no durability period in years, so the record should state the conditions tested and the result, rather than claim a period of durability that no test supports.
What sits behind the marking in the documentation?
For marking durability, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A production engineer trialling label materials on a battery enclosure 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 label on an industrial battery stored outdoors should be trialled under temperature cycling, moisture, and abrasion, and the trial should include a QR scan test after exposure, not only a visual check.
How is a marking checked line by line?
For marking durability, 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 durability trial record, material specification, and sample retention for the check should include the date, the sample identifier, and the version of each document compared. A production engineer trialling label materials on a battery enclosure should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. The Regulation sets no durability period in years, so the record should state the conditions tested and the result, rather than claim a period of durability that no test supports.
How is a durability trial run for one marking method?
A durability trial for one marking method starts with sample batteries marked by the production method, on the production surface. The samples are exposed to the conditions of the application: temperature cycling, humidity, abrasion, and any relevant chemical contact, for a stated duration. After exposure, each sample is checked visually and by QR scan, and the result is recorded per sample, not as an average. A worked trial for an outdoor industrial battery shows five samples, the exposure conditions, and the scan result for each sample after exposure. A method that passes visual inspection but fails the QR scan after abrasion fails the trial, because the QR code is part of the marking, not an extra.
| Durability factor | Trial | Pass measure |
|---|---|---|
| Abrasion and handling | Rub and handling trial | Text legible, code scannable |
| Moisture and temperature | Cycling and humidity trial | No lifting, no fading beyond legibility |
| Chemical exposure | Relevant substance contact | Marking remains legible and scannable |
Durability is proven by a trial on the actual surface, and a material datasheet alone does not prove that a marking will survive on this battery.
Sources & further reading
- Regulation (EU) 2023/1542, consolidated text, EUR-Lex ↗
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals ↗
- Regulation (EU) 2019/1020 on market surveillance, retained text ↗
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.