Safety and marking fields: CE marking, symbols, warnings and safety measures in a passport

Safety and marking fields cover two related but distinct subjects: the marking that appears on the battery itself, and the safety information that the passport holds in the authorised tier. Article 13 sets out labelling and marking, including general information, capacity, the separate collection symbol, chemical symbols, the CE marking position, and the QR code. Annex XIII point 1 requires marking and conformity information in the public summary, and point 2 requires safety measures in the authorised tier.

A reader who confuses the marking with the safety information will expect the battery surface to carry detail that belongs in the record, or will expect the record to replace the marking. Neither expectation is correct.

What marking appears on the battery?

The battery must bear, in visible, legible and indelible form, the information Article 13 requires for its category: manufacturer identification, battery model identification and batch or serial number, category, capacity, chemistry information as required, the separate collection symbol, and chemical symbols for cadmium or lead where the thresholds require them. The CE marking must be affixed visibly, legibly and indelibly before placing on the market, where the conformity assessment procedure requires it, and may be followed by the notified body identification number where applicable. Where the battery is too small or the marking cannot be placed on the battery for another stated reason, Article 13 provides for placement on packaging or in accompanying documentation. The passport record should state where the marking appears, so that a reader who cannot find marking on the battery knows where to look. Marking is a physical fact. The record describes it. The record does not replace it.

What is the separate collection symbol and why does it matter?

The separate collection symbol, the crossed out wheeled bin, indicates that the battery must not be disposed of as unsorted municipal waste and must be collected separately. The symbol appears on the battery, and the passport record shows waste prevention and management information that explains the collection route in general terms. The symbol is not a recycling claim and not a statement that the battery will be recycled. It is an instruction about disposal route. A record that describes the symbol correctly keeps disposal information separate from sustainability claims. A reader who sees the symbol should understand the collection duty, not infer a recycled content share or a carbon figure. Waste information in the passport includes the information Article 74 requires on prevention and management, including the role of the end user in separate collection, stated in general terms for the category.

What safety measures sit in the authorised tier?

Safety measures in Annex XIII point 2 include the measures that a person working on the battery needs to know: hazards associated with the battery, precautions for handling, storage and transport, measures for dealing with damaged batteries, and warnings relevant to dismantling. The measures are written for a knowledgeable reader with a legitimate interest, such as a repairer or recycler, and they assume the safety information and instructions that accompany the battery. The public tier does not reproduce the full safety detail, because the detail includes dismantling and handling information that requires competence and context. The public summary should nevertheless make clear that safety measures exist in the authorised tier and that the battery must not be opened or dismantled without them. A public view that gives no indication of safety detail invites unsafe handling by omission.

How are warnings and instructions linked?

Instructions and safety information must accompany the battery in a language easily understood by end users in the Member State where the battery is placed on the market, under Article 38 for manufacturers. The passport record links to the existence of that information without reproducing it in full. Warnings in the record, such as warnings about risk of damaging parts during disassembly, are model level warnings in the authorised tier. They do not replace the warnings in the instructions. The link between record and instructions should be explicit: the record states that instructions exist, the form in which they are provided, and the language position in general terms, so that a reader can obtain them. A record that reproduces a warning without its context, or that omits a warning that the instructions contain, creates a mismatch that a later reader cannot resolve from the record alone.

What does the marking and safety table show?

What must marking and safety fields never claim?

Marking and safety fields must never claim that a battery is safe to handle, open or repair without precautions, that CE marking proves every duty is met, or that a symbol proves a sustainability outcome. CE marking indicates conformity with the applicable Union harmonisation legislation for the conformity assessment performed. It is not a general safety guarantee and not a substitute for the safety measures in the authorised tier. This guide gives general educational information only and does not give legal advice for a particular battery, marking or safety decision.