How the battery QR code for the Digital Product Passport should be designed

Introduction

Regulation (EU) 2023/1542 on batteries and waste batteries has made batteries the first product category to require a mandatory digital passport within the European Union. The gateway to this passport is an ostensibly simple object: a QR code.

Simple, that is, only at first glance. This small square must comply with two articles of the Regulation (Articles 13 and 77), contain an identifier that adheres to the ISO/IEC 15459 series of standards, remain intact throughout the entire lifespan of the battery, and stay linked to structured, interoperable data registered within the European digital passport registry.

In this article, we examine, point by point, how it must be designed.

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1. Two Articles, One Code

The QR code for batteries stems from the intersection of two provisions:

• Article 13 – Labelling and marking: This establishes that all batteries must feature a QR code, where it must be placed, and what it must provide access to.
• Article 77 – Battery passport: This defines how the identifier—to which the QR code points—must be constructed for batteries subject to the passport requirement.

The Key Date: February 18, 2027

According to Article 13, paragraph 6, as of February 18, 2027, all batteries must be marked with a QR code that complies with Annex VI, Part C. On the same date, Article 77, paragraph 1 mandates a passport for three specific categories of batteries.

Note: The requirement for a QR code is broader in scope than the requirement for a passport. Even a portable battery or an automotive starter battery must carry one. only what the code links to changes.

What the QR code must lead to

Battery category	The QR code provides access to	Reference
Batteries for light means of transport (LMT)	Battery passport	Art. 13(6)(a), Art. 77
Industrial batteries with a capacity > 2 kWh	Battery passport	Art. 13(6)(a), Art. 77
Electric vehicle (EV) batteries	Battery passport	Art. 13(6)(a), Art. 77
Other batteries (e.g., portable)	Label information (Art. 13, paragraphs 1–5), EU declaration of conformity (Art. 18), due diligence report (Art. 52(3)), information on waste prevention and management (Art. 74(1), points a–f)	Art. 13(6)(b)
Starting, lighting, and ignition (SLI) batteries	In addition: the share of cobalt, lead, lithium, or nickel recovered from waste present in the active materials (Art. 8)	Art. 13(6)(c)

The Regulation further specifies that this information must be complete, up-to-date, and accurate. A QR code that leads to an empty, outdated, or generic page is not compliant.

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2. Physical requirements: where and how the QR code must be affixed

Visible, legible, and indelible (Art. 13, paragraph 7)

The QR code must be printed or engraved on the battery in a way that is visible, legible, and indelible. Only if the nature or dimensions of the battery do not allow or justify it may the code be placed on the packaging and accompanying documentation.

For batteries subject to the battery passport requirement, this exception should be used with caution: an EV or industrial battery may undergo dismantling, repair, reuse, and eventually recycling—and at each of these stages, the operator must be able to scan the code. A QR code printed only on the box would be lost the moment the battery is installed.

Contrast and dimensions (Annex VI, Part C)

Annex VI, Part C requires that the QR code:

• have high contrast relative to the background color;
• be of a size that allows for easy reading by commonly available QR code scanners, such as those integrated into smartphones.

The Regulation does not specify a minimum size in millimeters; the appropriate dimensions depend on the amount of encoded data, the level of error correction, and the intended scanning distance.

Symbology: ISO/IEC 18004

Recital 44 of the Regulation refers to the ISO/IEC 18004 standard, which defines the QR Code symbology. In practical terms, the code must be a "true" QR Code—generated and verified in accordance with this standard—rather than a proprietary variant. The recital also addresses the accessibility of labels and QR codes for persons with disabilities, in line with Directive (EU) 2019/882.

Long-term Durability

An industrial or traction battery may remain in service for ten to fifteen years, exposed to vibrations, heat, humidity, and solvents. This necessitates specific design choices:

• laser marking or direct engraving on the casing, or the use of labels made from technical materials (polyester, polyimide) with certified adhesives;
• a high error correction level (Q or H, according to ISO/IEC 18004) to ensure readability despite scratches or dirt;
• a clear "quiet zone" (buffer area) around the symbol;
• print quality verification using methods and verifiers that comply with ISO/IEC 15415 and 15426-2 standards;
• optional inclusion of the identifier in human-readable text alongside the symbol, which serves as a fallback should the code become damaged.

Repurposed and Remanufactured Batteries (Art. 13, Para. 9)

Batteries that have been prepared for reuse, repurposed, or remanufactured must bear new labels, and the QR code must provide access to information regarding the change in the battery’s status (Annex XIII, Point 4).

The QR Code Is Not Permanent (Art. 13, Para. 8)

In light of technical progress, the Commission may adopt delegated acts to introduce other types of "smart labels"—either in addition to or as a replacement for the QR code. Designing the system by separating the identifier, the syntax, and the physical medium (see Section 4) makes any such transition easier to implement.

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3. The Unique Identifier (Art. 77, Para. 3)

Here, the focus shifts from the "design" of the code to its content. Article 77, paragraph 3, stipulates that:

1. the passport is accessible via the QR code referred to in Article 13(6);
2. the QR code links to a unique identifier assigned to the battery by the economic operator placing it on the market;
3. the QR code and the unique identifier must comply with the ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014, and 15459-6:2014 standards, or equivalent standards.

Two important observations:

• "or equivalent": The Regulation establishes a level of requirement (global uniqueness, issuance under a registered authority) rather than mandating a specific technology or provider.
• Updatability: The Commission may replace or supplement the list of standards through delegated acts.

For batteries subject to the passport requirement, the identifier applies at the individual battery level, not the model level: the passport contains both model-related data and data specific to the individual unit, including information derived from its use (Art. 77, para. 2).

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4. ISO/IEC 15459 in practice

What the six parts cover

Part	Scope
ISO/IEC 15459-1	Individual transport units
ISO/IEC 15459-2	Registration procedures (who is authorized to issue identifiers)
ISO/IEC 15459-3	Common rules for unique identifiers
ISO/IEC 15459-4	Individual products and product packages — the most relevant part for an individual battery
ISO/IEC 15459-5	Reusable transport items (RTIs)
ISO/IEC 15459-6	Groupings (batches, lots)

How a compliant identifier is constructed

The principle is hierarchical and ensures uniqueness on a global scale:

1. Registration Authority: The association AIM acts as the ISO registration authority for the 15459 series and assigns Issuing Agency Codes (IAC).
2. Issuing Agency: A recognized issuing body (e.g., GS1) assigns an identification code—known as a Company Identification Number (CIN), or a Company Prefix in the GS1 system—to each company.
3. Company: The economic operator generates a unique serial number for each individual battery within its own assigned space.

Result: IAC + CIN + serial number = an identifier that cannot be duplicated by anyone else in the world.

AIM has also launched an online lookup service (IAC-CIN Lookup Service) to verify issuing bodies, which is also designed to support the requirements of the digital product passport.

Three levels that should not be confused

One of the most common errors is conflating three distinct concepts:

Level	Question	What the regulation states
Identifier	How do I uniquely identify the battery on a global scale?	ISO/IEC 15459 series or equivalent (Art. 77(3))
URL Syntax	How do I write the identifier in the form of a resolvable web address?	Free choice among compliant syntaxes—for example, GS1 Digital Link, IEC 61406, or ISO/IEC 18975
Data carrier	On what physical medium should I place the URL?	A QR code is mandatory (Art. 13(6), Annex VI, Part C); other carriers may be added

GS1 Digital Link is not a legal requirement: while it is the most widely used syntax and a natural choice for those already employing GTINs, the Regulation does not mandate it.

An illustrative example

Using the GS1 Digital Link syntax, a QR code on a battery could encode a URL such as:

https://id.example-manufacturer.eu/01/09506000134352/21/BAT27A000123

where:

• 01 introduces the GTIN (identifying the battery model);
• 21 introduces the serial number (identifying the individual battery);
• the domain acts as a resolver that directs the user to the passport, displaying either public or restricted data depending on the user's access profile.

This example is purely for demonstration purposes: the domain, GTIN, and serial number are fictitious.

Best practices for code content

• Short URLs: fewer characters result in a less dense, smaller, and more robust QR code.
• A stable domain under the operator's control: the printed URL will remain on the battery for years, whereas IT systems may change over time.
• No sensitive data in the URL: the code is intended for identification, not for carrying confidential information.
• Avoid "marketing" links or temporary redirects that might expire.

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5. From QR code to passport: what should be "behind" it

A perfect QR code is not enough if the destination it points to is not compliant. Article 77 also establishes the following requirements:

• Multi-level access (para. 2): The information listed in Annex XIII is categorized into public data (accessible to anyone who scans the code), data restricted to notified bodies, market surveillance authorities, and the Commission, and data accessible only to parties with a legitimate interest (repairers, remanufacturers, second-life operators, and recyclers).
• Responsibility (para. 4): The economic operator placing the battery on the market must ensure that the information is accurate, complete, and up-to-date; they may delegate this responsibility to other parties in writing.
• Open standards (para. 5): Data must be based on open standards, provided in an interoperable format, transferable via an open network without being tied to a single provider (vendor lock-in), and must be machine-readable, structured, and searchable.
• Second life (para. 7): Batteries that are reused, repurposed, or remanufactured are assigned a new passport linked to the original one; this includes a new unique identifier and, typically, a new QR code.
• End-of-life (para. 8): The passport ceases to exist once the battery has been recycled.
• EU Registry (para. 10): The operator must upload the unique identifier to the digital passport registry provided for under Article 13(1) of the ESPR Regulation (EU) 2024/1781. This registry will be operational as of July 2026.

Article 78 adds a requirement for full interoperability with other digital product passports mandated by ecodesign legislation. In this context, the European standards developed by CEN-CENELEC JTC 24 for the Digital Product Passport (the EN 18216–18223 series—including EN 18219 on unique identifiers and EN 18220 on data carriers) serve as a key reference.

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6. Design Checklist

Before moving to production, ensure that your QR code:

• is generated in accordance with ISO/IEC 18004 (the standard QR Code symbology);
• encodes a unique identifier that complies with the ISO/IEC 15459 series (or equivalent) and is issued by a recognized issuing authority;
• for EV, LMT, and industrial batteries > 2 kWh, identifies the individual battery rather than just the model;
• uses a recognized URL syntax and a stable domain under your control;
• features high contrast and is of a size that is readable by a standard smartphone;
• is printed or engraved on the battery in a visible, legible, and indelible manner (placing it on packaging or documentation should only be done if absolutely unavoidable);
• is resistant to heat, vibrations, abrasion, and solvents throughout its intended service life;
• has passed a print quality verification;
• links to content that is complete, up-to-date, and accurate, with access tailored to specific user profiles;
• has its identifier registered in the EU registry for digital product passports;
• includes provisions for managing new identifiers and new labels for batteries that have been remanufactured or repurposed. ---

7. Pitfalls to Avoid

1. Assuming that QR codes are only required for batteries that have a "passport." As of February 18, 2027, they will be required for all batteries.
2. Believing that GS1 Digital Link is mandatory. It is one valid option, but not the only one.
3. Using a model identifier for an individual passport. For EV, LMT, and industrial batteries (> 2 kWh), each individual battery must have its own unique passport.
4. Relying solely on the outer packaging. For long-life batteries, the code must be placed directly on the battery itself.
5. Linking to a URL or platform outside of your control. The Regulation explicitly prohibits vendor lock-in.
6. Overlooking the EU registry. A passport is not considered complete from a regulatory standpoint unless the identifier has been uploaded to the registry.

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Conclusion

The battery QR code is much more than just a label.