# Battery Passport & EU Battery Regulation Compliance (2026) | SmartLinks Battery Passport software for EU Battery Regulation 2023/1542. Annex VI QR labelling from 18 August 2026, full Article 77 battery passport from 18 February 2027. Generate the printed label, QR target and passport record for every battery — AA cells to EV traction — placed on the EU market. Also known as the Battery DPP. Canonical URL: https://www.smartlinks.app/solutions/batteries Battery Passport and Annex VI QR labelling software for the EU Battery Regulation. One platform for the 18 August 2026 label deadline, the 18 February 2027 full passport, and every downstream EPR, carbon footprint and recycled-content disclosure — from AA cells to EV traction. ## Every battery sold into the EU now needs a Battery Passport and QR label. In under three months — from 18 August 2026 — every battery placed on the EU market, including a blister pack of AAs, must carry an Annex VI QR with chemistry, EPR registration, hazardous substances and safe-handling data. From 18 February 2027, industrial (>2 kWh), LMT and EV cells also need the full Article 77 Battery Passport (the "Battery DPP"). SmartLinks delivers both, on the same digital twin. ### August 2026 label & QR · February 2027 full passport The QR label applies to every battery, every chemistry, every form factor. The full passport applies to industrial >2 kWh, light means of transport (e-bikes, e-scooters), and EV cells. SmartLinks treats both as the same data object — you set up the record once and the platform serves the right view to consumers, recyclers and regulators. - **Printed label + QR** (18 Aug 2026) - **Full battery passport** (18 Feb 2027) - **Carbon footprint (portables)** (Phasing to 2030) - **Recycled-content thresholds** (2027–2031) ### Everything Annex VI asks for —issued, hosted and version-controlled. We turn the regulation into a structured record: chemistry, weight, capacity, hazardous substances, separate-collection symbol, manufacturer details, EPR registration numbers per Member State, recycled-content percentages, carbon footprint and the Article 11 removability declaration. - **Annex VI printed label** — Compliant print-ready artwork — wheelie bin symbol, chemistry, Cd/Pb/Hg call-outs, CE mark and the QR placed exactly where the regulation expects it. SVG + PDF export, per SKU or per batch. - **QR-linked record** — One scan returns the consumer view, the operator view, the recycler view and the regulator view — role-aware, no logins for public data. GS1 Digital Link resolver, batch- or unit-level. - **EPR & take-back** — Per-Member-State producer registration numbers stored against the record. Nearest collection point surfaced on every scan. 27 jurisdictions, one source of truth. - **Carbon footprint** — Per-SKU CFP value with the underlying PEF dataset attached as a verifiable attestation. Performance class and threshold once published. EV from 2025, industrial 2026, LMT 2028, portables ~2030. - **Recycled content** — Cobalt, lithium, nickel and lead percentages held against the proof, machine-readable for procurement, regulators and disclosure indices. Thresholds phasing 2027–2031. - **State-of-health & due diligence** — For industrial, LMT and EV: SoH/SoC writes back from the field, raw-material due-diligence dossier attached as evidence. Required for the full Article 77 passport. ### Five product profiles — one compliance pattern. The regulation scopes obligations by battery category. We've mapped the typical product profile we see at each tier so you can find yours quickly. - **Portable primary cells** — AA, AAA, 9V, coin and button cells sold in blister packs. - Annex VI printed label + batch-level QR - No full passport required - EPR registration per Member State - Stock-in-trade grace under Article 96 - **Cordless tool & appliance packs** — Power tool batteries, robot vacuum and cordless appliance packs, typically <2 kWh. - Annex VI label + QR mandatory - Article 11 removability declaration - Carbon footprint phasing in for portables - Retailer-driven passport-grade data pressure - **Light means of transport (LMT)** — E-bikes, e-scooters, e-mopeds — any vehicle <750 W wheel power. - Full Article 77 battery passport - Unique per-unit identifier - SoH/SoC + cycle history - CFP declaration from August 2028 - **Industrial >2 kWh** — BESS, telecoms backup, forklift and industrial battery packs above 2 kWh. - Full battery passport from Feb 2027 - Due-diligence dossier on raw materials - Performance-class declaration - Recycled-content thresholds 2031 - **EV traction** — Battery electric and plug-in hybrid vehicle traction packs. - Full passport + per-cell identity - CFP class assigned at sale - Second-life and repurpose routing - Regulator API access required - **Own-label & importer** — Supermarket-brand AAs, white-label power tool packs, BESS importers. - Importer = producer under EU rules - EPR registration in every selling Member State - Liability sits with the entity on the label - Supplier-data passthrough into your record ### What the regulation asks — what SmartLinks delivers Every Annex VI and Article 77 requirement maps to a capability already running on the SmartLinks platform. You configure the data; we handle the label, the QR target, the role-based views and the audit trail. - **Printed Annex VI label artwork** (2026) — Per-SKU SVG/PDF with chemistry, CE, wheelie-bin, hazardous-substance call-outs and QR placement. - **QR-linked digital record** (2026) — GS1 Digital Link resolver, batch- or unit-level, role-aware views for consumer/operator/recycler/regulator. - **EPR registration disclosure** (2026) — Per-Member-State producer registration numbers held against the record, surfaced on every scan. - **Separate-collection routing** (Now) — Nearest take-back location resolved on scan; recycler hand-off logged automatically. - **Carbon Footprint Declaration** (2026) — PEF-aligned CFP value + performance class + threshold, dataset attached as verifiable attestation. - **Recycled-content percentages** (2027) — Cobalt, lithium, nickel, lead — machine-readable, attestation-backed. - **Article 11 removability declaration** (2027) — Spare-parts catalogue, exploded views and removal documentation linked to the twin. - **State of Health & Charge (industrial/LMT/EV)** (2027) — Field-write API; SoH/SoC aggregable per fleet and visible to the owner on scan. - **Due diligence on raw materials** (2027) — Supplier attestations and audit trail attached as verifiable evidence. ### From spreadsheet to passport in days, not quarters. The same digital twin platform that runs SmartLinks Hub, the EU DPP and GS1 Digital Link resolver underpins the battery record. You bring the data; we generate the label, host the record and serve the QR target. - **1. Set up the battery profile** — Pick the category, declare chemistry, capacity, weight and hazardous substances. The platform shows you exactly which fields the regulation requires for that profile. - **Category-aware schema** — Portable, LMT, industrial, EV — only the right fields appear. - **EPR registry per market** — 27 Member State registration numbers in one place. - **CFP & recycled content** — Attach the PEF dataset and supplier attestations. - **2. Generate label & QR** — Annex VI-compliant artwork drops out as print-ready SVG and PDF. The QR resolves to a role-aware record — batch- or unit-level depending on the category. - **Print-ready artwork** — SVG + PDF, per SKU or per batch, with correct symbol placement. - **GS1 Digital Link target** — One QR, every endpoint — consumer, recycler, regulator. - **Role-aware views** — Public scan vs operator vs regulator handled by the platform. - **3. Keep it live** — Field updates, SoH telemetry, second-life routing and end-of-life hand-off all write back to the same record — for the full ten-year retention window the regulation expects. - **SoH / SoC write-back** — Required for industrial, LMT, EV; useful everywhere. - **Take-back & second life** — Nearest collection point on scan; routing logged. - **Versioned audit trail** — Every change retained — defensible for regulators. ### One platform, every overlap. Most battery-bearing products carry obligations under more than one regulation. A cordless drill has an Electronics DPP (ESPR) and a battery label (Battery Regulation). An e-bike has both, plus an LMT passport. SmartLinks handles the overlap so you don't end up with three vendors and three QR codes. - **GS1 Digital Link** — One QR per product, multiple endpoints, indefinitely versioned. - **EU DPP & ESPR** — Furniture, textiles, electronics, batteries — same record, different views. - **Authenticity & anti-counterfeit** — Cryptographic proofs for high-value packs and EV cells. - **Owner & fleet accounts** — Battery registration, warranty, recall reach — without rebuilding CRM. ### FAQ **Does this really apply to a pack of AA batteries?** Yes. The August 2026 labelling and QR requirement under Article 13 and Annex VI applies to every battery placed on the EU market — portable primary cells included. The full Article 77 passport is narrower (industrial >2 kWh, LMT, EV), but the printed label and QR target are universal. Batch-level QR is permitted for portables, so one QR per SKU/batch is enough. **Is there a grace period?** Article 96 lets batteries placed on the market before 18 August 2026 sell through without the new label. Given primary cells have multi-year shelf lives, unlabelled stock will be on EU shelves into 2027–2028. The Commission's implementing act for the QR data format and CEN/CENELEC standards (prEN 18222 et al.) are still landing, so enforcement will be soft initially — but the legal deadline is fixed. **We sell in the UK only. Does this affect us?** GB has not onshored Regulation 2023/1542 and still operates under the 2009 Batteries Regulations. Northern Ireland follows the EU regime under the Windsor Framework. If you sell into the EU — or into NI — you need to comply. Most UK brands also align voluntarily because retailers, marketplaces and Scope-3 reporting frameworks already ask for the data. **Does a cordless drill need two passports — one for the battery and one for the tool?** Effectively, yes. The drill itself falls under ESPR-driven Electronics DPP rules; the removable battery pack falls under the Battery Regulation. SmartLinks treats both as views over the same digital twin, so the QR on the tool and the QR on the pack resolve to the right record without duplicating data. **Can we use one QR for a whole batch instead of per cell?** For portable primary cells (AA/AAA/coin) and for non-rechargeable categories, batch-level QR is permitted and standard. For industrial >2 kWh, LMT and EV the regulation requires unique per-unit identifiers — one QR per battery. The platform handles both modes from the same configuration. **What if our supplier data isn't ready yet?** We model the record now with placeholders and version it as supplier attestations arrive. The QR resolver returns the most recent verified version, so you can ship compliant labels in stages rather than waiting for a perfect dataset. ## Further reading - [Battery Compliance Deep Dive](/resources/battery-compliance) — eight-tab walkthrough of Article 11, the QR label, CFP phasing, EPR, worked examples and the playbook by company profile. - [Battery Passport guide](/guides/battery-passport) — the regulation explained with the five Article 3 categories and what each must carry. - [Does your cordless drill need two DPPs?](/blog/cordless-drill-battery-vs-electronics-dpp) — battery vs electronics passport, and what to do when the battery is built in. - [DPP Timeline 2026–2032](/resources/dpp-timeline) — every regulation, deadline and category in one view. - [Electronics & e-waste DPP guide](/guides/electronics-ewaste-dpp) — for the host appliance side of the overlap. - [Platform DPP](/solutions/platform-dpp) — the cradle-to-grave platform that underpins every category of passport. ### Official sources - [Regulation (EU) 2023/1542 — full text](https://eur-lex.europa.eu/eli/reg/2023/1542/oj) (EUR-Lex). - [European Commission — Batteries and accumulators](https://environment.ec.europa.eu/topics/waste-and-recycling/batteries-and-accumulators_en). - [Global Battery Alliance — Battery Passport](https://www.globalbattery.org/battery-passport/) (industry reference standard). ### Get your Battery Passport ready before the 18 August 2026 deadline. We'll show you the live battery record, the print-ready Annex VI label and the QR resolver in a 30-minute working session — using one of your own SKUs. - Book a Battery Passport Briefing: https://calendly.com/prove-anything/prove-anything-discovery-meeting - Talk to Compliance Team: /contact --- _Generated from SmartLinks solutions registry._