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Battery Passport vs a Printed Product Label: What Changes?

A printed label still exists, but it can no longer carry the full battery passport — the regulation requires a digital, tier-gated record reachable through a QR-linked data carrier, keeping only minimal markings on the physical product.

Last updated 1 June 2026

A printed label is a static surface: it shows what fits on the product and never changes after printing. The battery passport is the opposite — a structured digital record that different audiences read at different access levels, updated over the life of the battery and reachable through a data carrier such as a QR code. The label does not disappear, but it stops being the place where compliance data lives.

Static print versus a live record

Regulation (EU) 2023/1542 requires a passport per individual battery with item-level data — state of health, status and life-cycle events — that cannot exist on ink. The physical product keeps only minimal markings (such as the data carrier and the unique identifier), while the regulated content sits behind the passport URL with the Annex XIII access tiers enforced server-side.

AspectPrinted labelBattery passport
MediumInk on the productDigital record at an immutable URL
Updatable after saleNoYes, for item-dynamic data
Access tiersEverything visible at onceAnnex XIII tiers enforced server-side
CapacityLimited by print areaFull Annex XIII data set
Per individual batteryHard to maintainNative (Art. 77(1))
10-year retentionDegrades, can be lostProvided as a durable service
The label and the passport are not competitors. The product still carries a data carrier and unique identifier; the passport is what that data carrier resolves to.
  • Keep the minimal physical markings and the QR-linked data carrier on the product.
  • Move the full Annex XIII content into the digital passport, gated by access tier.
  • Maintain item-dynamic data after sale — something a printed label cannot do.
  • Ensure the passport URL stays reachable for the full retention period.

Frequently asked

Does a printed label still count as a battery passport?

No. A printed label cannot carry the full Annex XIII data set, cannot enforce access tiers and cannot be updated over the life of the battery. The regulation requires a digital passport per individual battery, reachable through a data carrier such as a QR code.

Do I still need any printing on the battery?

Yes. The physical product keeps minimal markings, including the data carrier and the unique identifier, which resolve to the digital passport where the regulated content lives.

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