Specialist QR and Marking for Battery Passports

QR and marking for specialist batteries follow the same Regulation framework as for other batteries, with a QR code that gives access to information about the battery, and, for batteries within Article 77, access to the battery passport. The specialist question is placement and durability, because a specialist battery may be fitted in a way that hides the marking, may operate in an environment that damages a label, or may be part of a larger system where the battery marking is not visible without dismantling. Those placement questions do not change the marking duty, but they change how the duty is satisfied in practice, and a marking that cannot be read where the battery is installed is a weak satisfaction of the duty even when the marking exists somewhere on the battery.

The scope is the marking and QR duties in Article 13 of Regulation (EU) 2023/1542, read with Article 77 for passport batteries, for specialist batteries inside the Regulation. The guide does not state marking specifications for any particular battery or equipment. The position is stated as checked on 28 October 2026.

What marking does Article 13 require?

Article 13 requires batteries to be marked with information including the crossed out wheeled bin symbol, capacity information and, from 18 February 2027, a QR code, with the precise marking elements set out in Article 13 and Annex VI. The QR code gives access to the information that Article 13 requires, and for passport batteries the data carrier gives access to the passport itself. A reader should check the Article 13 text for the battery category in question, because the marking elements vary by category and by date, and a general statement that a battery needs a QR code does not state which information the QR code must give access to. The marking duty and the passport duty share a date for passport batteries, but they are distinct duties, and a battery can carry a QR code without carrying a passport where the passport duty does not apply.

How does the QR code reach the passport?

The QR code reaches the passport by resolving to the electronic record for the individual battery, identified by the unique identifier, rather than by containing the record itself. The separation matters for specialist batteries, because the printed code cannot change while the record behind it must stay current, and a code that resolves to the wrong record, to a model record instead of an individual record, or to no record, fails the access purpose even when the code itself scans. A specialist operator should test the code at installation, at handover and at collection, recording the date and the result of each test, so that a code failure is found early rather than at the moment when the record is needed most. Testing is a record practice, and the test results belong in the battery file.

What placement questions arise for specialist batteries?

Placement questions arise where the battery is enclosed, fitted in a system, installed in a fixed location or operated in a harsh environment, because the marking must remain accessible, legible and durable for the life of the battery. A marking placed on a surface that is hidden by installation, covered by a housing or damaged by the operating environment will not serve a later reader, even though the marking was correct at manufacture. The placing operator and the installer should therefore agree, before installation, where the marking will sit, how it will be reached without dismantling where the Regulation requires access, and how its durability will be preserved. The agreement should be recorded, because a later dispute about access will turn on what was agreed and what was done.

What does a marking check table look like?

A marking check table separates the code, the resolution, the placement and the durability, so that a failure in one element is not hidden by success in another. The table below uses general check elements.

What happens when a QR code is damaged in a specialist setting?

When a QR code is damaged, the record link is broken for a reader who relies on scanning, and the remedy is to recover the identifier from other sources, such as the battery marking, the accompanying documents or the record system, and to restore access without creating a duplicate record. A damaged code does not erase the passport, and a new code that resolves to a new record for the same battery creates a duplication problem that is worse than the damage. The correct remedy preserves the existing identifier and restores the carrier, with the damage and the remedy recorded in the file. The damaged code guide in the questions cluster describes the general remedy, and the specialist version adds the placement and durability questions that caused the damage.

How does marking fit with system documentation?

Marking fits with system documentation as the physical link between the battery and its record, while system documentation describes the installation, the operation and the maintenance of the whole system. The system documents should name each battery by identifier and state where the marking for each battery can be found, so that a later operator can move from system to battery to record without searching. A system file that describes the system without naming the batteries, or a battery record that cannot be found from the system file, leaves a gap that a later operator must bridge by inspection. The bridge should be built at installation, when the information is at hand, rather than at collection, when it may be lost.

What limits apply to marking readings?

The limits are that marking specifications turn on category and date, and this guide states them only in general terms. This guide gives general educational information only and is not individual legal advice. An operator with a specific battery should check Article 13 and Annex VI as checked on 28 October 2026 before acting.