Supplier quick plan

Rechargeable battery label & QR

Capacity is required for rechargeable portable batteries; “rechargeable battery” is a useful clarity statement, not a separate wording duty in Article 13.

NOW

Verify the model

Use exact-model test reports, SDS/MSDS, traceability data and the EU Declaration of Conformity.

18 FEB 2027

QR mandatory

Publish complete, stable and current digital information for the exact battery.

COMMISSION DRAFT

Prepare detailed fields

Exact chemistry, substances, critical raw materials and supported extinguishing agent / EN 2 fire class.

QR content exampleLegal status

Duty overview - rechargeable batteries

Applies to loose rechargeable portable batteries such as NiMH AA/AAA cells and to rechargeable portable batteries built into products. Product design for user replacement remains on the separate replaceable-design page.

Requirement Cell Manual Packaging QR Article
Brandname / producer identification ✓ — ✓ ✓ Art. 13(1)
battery category and model identifier ✓ — ✓ ✓ Art. 13(1)
place of manufacture and manufacturing month/year: YYYY-MM ✓ — ✓ ✓ Annex VI
weight, exact chemistry, hazardous substances, critical raw materials and usable extinguishing agent / EN 2 fire class (Commission draft) ✓ — ✓ ✓ Art. 13(1)
capacity in mAh; add Wh for Li-ion packs and products where energy content matters ✓ — ✓ ✓ Art. 13(2)
CE, crossed-out wheeled bin, lot/serial code ✓ — ✓ ✓ Art. 13(4)-(5)
safe charging, use and storage instructions — ✓ — — Art. 38(4)
heat, fire, short-circuit and child-safety warnings — ✓ — — Art. 38(4)
disposal and separate collection instructions — ✓ — — Art. 74
replacement or service information where the battery is built in — ✓ — — Art. 11
link to online battery information and QR target page — ✓ — ✓ Art. 13(6)
complete manufacturer and importer details — — ✓ ✓ Art. 38
model, lot, manufacturing place and manufacturing date — — ✓ ✓ Art. 38
capacity, voltage, Wh where relevant, chemistry and weight — — ✓ ✓ Annex VI
composition, hazardous substances and critical raw materials over 0.1% — — ✓ ✓ Annex VI
safety, charging, recycling and disposal warnings — — ✓ ✓ Art. 12
GTIN/SKU, model, producer, importer — — — ✓ Art. 13(6)
capacity, voltage, Wh, chemistry and weight — — — ✓ Annex VI
manufacturing place and manufacturing date — — — ✓ Annex VI
safety, charging, replacement and recycling information — — — ✓ Art. 13(6)
compliance links and document references — — — ✓ Art. 13(6)
No requirements found.
Art. 13(1): general information for all batteries Art. 13(2): capacity marking for rechargeable portable batteries Art. 13(4)-(7): QR, symbols and small-battery handling Annex VI Part A: battery label data fields Art. 11: replaceable design where battery is built into product

Capacity marking: mAh and Wh

What the EU rule says
  • From the label trigger date, rechargeable portable batteries must carry capacity information.
  • For AA/AAA rechargeable cells, mAh is the normal supplier-facing capacity value.
  • The Regulation does not state that every rechargeable portable battery must show both mAh and Wh as a fixed double unit.
Practical Mega Step artwork rule
  • For loose AA/AAA NiMH: show mAh; add Wh where space allows.
  • For Li-ion packs, power banks, and built-in battery products: show both mAh and Wh.
  • Formula: Wh = nominal voltage x Ah. Example: 3.7V x 2.2Ah = 8.14Wh.
This keeps the supplier artwork practical while avoiding a false statement that Wh is always explicitly required by Article 13(2) for every rechargeable portable battery.

What still belongs on packaging and documents

Packaging / manual / online information
Loose rechargeable AA/AAA
  • full manufacturer and importer details if they do not fit on the cell
  • model / IEC code, lot, chemistry, voltage, mAh, and optional Wh
  • charging, storage, short-circuit, child-safety, and disposal warnings
  • future QR target page and linked compliance information
Built-in rechargeable batteries
  • full manufacturer name, address, website, and email
  • full importer name, address, website, and email
  • product-specific battery service information where applicable
  • safety information for use, charging, storage, and disposal
  • future QR target page and linked digital product information
  • later battery label data under Annex VI Part A and capacity label logic
Do not mix the two cases: loose rechargeable AA/AAA cells are a battery artwork problem; built-in rechargeable batteries are a battery plus product documentation problem.

What the manual and online page must cover

Manual / insert
  • how to use and charge the product safely
  • where to find the separate replaceable-design and service information, where applicable
  • fire, heat, short-circuit, and child-safety warnings
  • disposal and separate collection instructions
Permanent online information
  • link to the replaceable-design guide, where applicable
  • battery safety and disposal information
  • future QR-linked product page structure
  • later DoC and compliance references
QR-Code

QR code and digital product information

Same requirements for all portable batteries. The QR code links to a target page with identification, label data, contacts, safety and recycling per Regulation (EU) 2023/1542.

  • suitable for later structured product data connection
  • language selection in the page header
  • safety, recycling and compliance information
  • for private-label products: show actual producer/factory in addition to brand and importer
  • for small cells: if QR cannot be placed on the battery, place it on both packaging and accompanying documents
Important for suppliers: brand, actual producer/factory and EU importer must remain clearly separated and traceable on the QR target page.
QR information →
Clickable example target page