QR marking vs passport marking

The QR code on a battery and the battery passport are linked but not identical. Article 13(6) requires a QR code on every battery from 18 February 2027, giving access to the information set out in that paragraph. For EV batteries, LMT batteries, and industrial batteries over 2 kWh, the QR code gives access to the battery passport under Article 77. For other batteries, the QR code gives access to the general labelling information, the EU declaration of conformity, the due diligence report where relevant, and waste prevention and management information. The record must state the battery category, the QR destination, and the unique identifier, and must test the code by scanning it. A printed code that leads nowhere is not a marking.

QR marking means the QR code affixed to a battery under Article 13(6) and (7). Passport marking means the use of that code as the data carrier for the Article 77 passport, linked to a unique identifier under the ISO/IEC 15459 series or an equivalent.

What is the legal frame for this marking?

QR marking and passport marking is a physical marking duty and a record duty at the same time. Articles 13(6) and 77(3) gives the operative requirement, and Annex VI gives the content and the form. A pack producer testing QR codes on finished packs before dispatch 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 finished EV pack should carry a QR code that, when scanned, resolves to the passport for that individual pack identifier, while a portable battery QR code should resolve to the general information and declaration for the model.

How are content, placement, and legibility checked?

Content asks whether every required element for QR marking and passport marking is present and correct for the battery category. The QR destination record, scan test log, and identifier register should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Annex VI Part C requires the QR code to be in high contrast to the background and of a size easily readable by a commonly available reader, and the scan test should use a common reader, not only a laboratory scanner.

How does category decide content?

Category decides content. For QR marking and passport marking, 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 pack producer testing QR codes on finished packs before dispatch should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A finished EV pack should carry a QR code that, when scanned, resolves to the passport for that individual pack identifier, while a portable battery QR code should resolve to the general information and declaration for the model.

How are measurement and wording recorded?

For QR marking and passport marking, 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 QR destination record, scan test log, and identifier register should include the test report or the calculation sheet, the date, and the person or function that approved the value. Annex VI Part C requires the QR code to be in high contrast to the background and of a size easily readable by a commonly available reader, and the scan test should use a common reader, not only a laboratory scanner.

What sits behind the marking in the documentation?

For QR marking and passport marking, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A pack producer testing QR codes on finished packs before dispatch 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 finished EV pack should carry a QR code that, when scanned, resolves to the passport for that individual pack identifier, while a portable battery QR code should resolve to the general information and declaration for the model.

How is a marking checked line by line?

For QR marking and passport marking, 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 QR destination record, scan test log, and identifier register for the check should include the date, the sample identifier, and the version of each document compared. A pack producer testing QR codes on finished packs before dispatch should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Annex VI Part C requires the QR code to be in high contrast to the background and of a size easily readable by a commonly available reader, and the scan test should use a common reader, not only a laboratory scanner.

How is a QR code tested end to end?

End to end testing starts with a scan using a common smartphone reader, in normal light, at a normal distance, on a finished battery. The scan must resolve to the correct destination: the passport for a passport battery, or the general information and declaration for another battery. The destination is then checked for the correct model, the correct identifier, and the correct document versions. A worked test log shows the battery identifier, the scan date, the reader used, the destination reached, and the result, for a sample of batteries from a batch. A code that resolves to a test page, a model page for another model, or a dead link fails the test, and the batch is held until the destination is corrected and retested.

A QR code is an address, not a document, and the record must prove that the address resolves to the correct record for the correct battery.