The Battery Data Carrier and QR Code: Labelling Rules Explained

A battery passport is only useful if people can find it. The EU Battery Regulation handles this with a data carrier: a mark on the battery that links to its passport. In practice that means a QR code. This guide explains what the data carrier is, what the labelling rules require, and how to prepare.

What a data carrier is

A data carrier is a machine-readable mark that points to the battery's passport. The regulation requires batteries to carry one so that scanning it takes the reader to the passport for that specific battery. The common, practical form is a QR code printed on or attached to the battery or its packaging.

The carrier does not hold the passport data itself. It holds a link that resolves to the hosted passport, which is why the passport has to stay online and reachable. See how long a passport must stay online.

What the labelling rules require

Labelling and marking sit in Art. 13 of Regulation (EU) 2023/1542, and for LMT, industrial over 2 kWh and EV batteries the QR code has to give access to the battery passport (Art. 13(6)). The regulation is specific about the mark:

• Placement. The QR code must be printed or engraved visibly, legibly and indelibly on the battery itself. Only where the battery's size or nature does not allow it may the code go on the packaging and the accompanying documents instead (Art. 13(7)).
• Timing. The QR code requirement applies from 18 February 2027, the same date as the passport (Art. 13(6)). The separate collection symbol has applied since 18 August 2025. The wider battery label runs on a different clock: Art. 13 sets its date as the later of 18 August 2026 or 18 months after the Commission's labelling act takes effect, so the real date follows that act. Check where it stands rather than assuming a fixed day.
• Purpose. For an in-scope battery, the code resolves to that battery's passport.

The standard behind the code

For the QR code to work reliably across the market, both it and the battery's unique identifier have to follow a recognised standard. The regulation requires them to comply with the ISO/IEC 15459 series on unique identifiers, or an equivalent (Art. 77). It does not name a particular commercial scheme. GS1 Digital Link is one common industry way to implement a conforming identifier as a web address, so that a single scan reaches the right record, but it is an implementation choice rather than the legal requirement. What the law fixes is the standard the code and identifier must meet; how you produce a conforming link is between you and your provider.

Preparing your labels

Because the carrier ends up on a physical label, it connects your compliance work to your production and packaging process:

1. Generate the passport first, so the carrier has a stable web address to point at.
2. Keep the web address stable. If the passport moves, the printed carrier breaks, so plan for the link to stay at the same address.
3. Fit the carrier into your label artwork with enough size and contrast to scan reliably, and confirm placement against the rules.

When it is time to move from a passport to printed labels, the practical steps are covered in our later guide on preparing QR data-carrier labels.

In short

The data carrier is the mark, in practice a QR code, that links a physical battery to its hosted passport. Art. 13 requires it to be printed or engraved on the battery (or on the packaging and documents where size does not allow), from 18 February 2027, and Art. 77 requires the code and unique identifier to meet the ISO/IEC 15459 standard, which GS1 Digital Link is one way to implement. Generate the passport first, keep its web address stable, and build the code into your label artwork.