QR codes, replaceable batteries and battery passports: the practical implications for brands selling equipment into the EU.

A battery inside your product is still a battery

If you manufacture wireless microphones, portable loudspeakers, battery-powered lighting, intercom systems, film equipment or portable power products, the EU Batteries Regulation may affect more of your range than you expect. The rules do not apply only to electric vehicles or dedicated battery manufacturers: batteries built into other products are covered too.

The next date is 18 February 2027. Two different requirements start that day, and they are easy to confuse: QR-linked information for batteries in general, and a fuller battery passport for specific categories.

What changes on 18 February 2027

1. QR-linked information for batteries in general: Under Article 13(6) of Regulation (EU) 2023/1542, batteries must carry a QR code linking to the information that applies to their category. For batteries that do not need a full passport, the QR code leads to the applicable label information, the EU declaration of conformity, the due diligence report where one is required, and information on preventing and managing waste batteries. The correct physical marking and placement must be checked for each product and battery configuration.
   
   For a manufacturer this is a data task before it is a labelling task: information held across technical sheets, suppliers, regulatory files and web pages has to be assembled, verified, published and kept current.
   
   

2. Removability, replacement instructions and spare parts: Article 11 sets requirements for products that incorporate portable batteries. In general the battery must be readily removable and replaceable by the end user, with specified exceptions. Instructions and safety information on use, removal and replacement must be permanently available online.

   
   Batteries must also be available as spare parts for at least five years after the last unit of the equipment model is placed on the market, at a reasonable and non-discriminatory price for independent professionals and end users. Software must not be used to impede replacement with a compatible battery or its key components.
   
   A digital product record can make instructions and spare-parts information accessible. It cannot, on its own, make a sealed battery removable or decide whether a legal exception applies: those are product design and compliance decisions.
   
   

3. Full battery passports for certain battery categories: A full battery passport is required from 18 February 2027 for electric vehicle batteries, light means of transport batteries such as e-bike batteries, and industrial batteries with a capacity above 2 kWh. This is more than a QR- linked web page: it involves an individual battery identity, category-specific data, access arrangements and the upload of the battery’s unique identifier to the EU digital product passport registry.
   
   A battery-powered stage light or wireless beltpack will not ordinarily need a full battery passport solely because it contains a portable battery. A large mobile energy-storage unit may. Note that a battery weighing more than 5 kg is an industrial battery unless it is a vehicle, light means of transport or starter battery, and an industrial battery needs a passport if its capacity is also above 2 kWh. Classification should be assessed against the finished battery, its weight, its capacity, its intended use and the relevant definitions.

Who is responsible

Battery passport duties fall on the economic operator that places the battery on the EU market or puts it into service. The removability, instructions and spare-part duties fall on whoever places the product containing a portable battery on the market. For take-back and registration, an EU-based brand that first supplies batteries under its own name in an EU country, including batteries inside its products, is the “producer” and must register in that country; for a brand outside the EU, its EU importer is the producer, unless the brand sells directly to end users at a distance. Which company in a supply chain holds each duty depends on who first supplies the battery or the product in the EU, so check it model by model.

The Regulation applies in the EU and in Northern Ireland. Great Britain has no battery passport or QR code requirement; it keeps its own older battery rules, including a removability rule. UK businesses should look at their EU and Northern Ireland routes first.

Why now

The dates are not moving: nothing adopted or voted postpones them, and the only exemption proposed in Parliament covers industrial and vehicle batteries supplied under contracts signed before August 2023.

Readiness is low. In a Commission survey of 91 mostly large firms in July 2026, 15 per cent were very confident of having the passport data ready by February 2027, and Germany’s VDE said on 13 October 2026 that many affected companies are not sufficiently prepared. Retailers and importers in the EU are being advised to check their suppliers.

Start with your product data

The hard part is usually not generating a QR code. It is knowing which battery category each model belongs to, finding reliable supplier documentation, keeping versions consistent and making the correct information available for the product’s whole working life.

A practical first step is to take two battery-powered models and map their battery chemistry, capacity, supplier documents, product identification, removal instructions, replacement information and sales territories. That shows which information is ready, which is missing and which needs legal or engineering review.

How TAZAAR AssetID helps

TAZAAR’s AssetID platform connects a physical product to a cloud-based digital record through a QR code. Manufacturers use it to organise and publish product and battery information, link technical documentation, make removal guidance and spare-parts statements accessible, and keep an item-level identity as the product is serviced, transferred or resold.

AssetID can carry the information set for battery-powered products today, with a model-level page following within weeks. It also earns its keep beyond regulation: product authentication, warranty registration, service history, traceability and better resale provenance.

For manufacturers of passport-category batteries, TAZAAR is looking for design partners to map product data and shape its full battery passport capability, targeted for around the second quarter of 2027. That capability is not available for the 18 February 2027 deadline and is not offered as a passport compliance solution today.

A five-point preparation checklist

1. Identify every battery-containing product sold into the EU or Northern Ireland, including accessories and spare packs.

2. Confirm the category, weight and capacity of each finished battery, and whether a full passport is required.

3. Review physical removability, compatible replacement options, supplier obligations and spare-parts plans.

4. Collect the QR-linked information, conformity documentation, recycling information and permanently available instructions.

5. Pilot a governed digital record and agree who owns updates when models, documentation or suppliers change.

Make the first step manageable

You do not need to begin by rebuilding your product database. Start with a short review of the battery-powered products you already sell. TAZAAR can show how AssetID turns existing information into useful product records and point out where further documentation or specialist compliance advice is needed.

Request a battery-product readiness review.

Sources: Regulation (EU) 2023/1542, Articles 11, 13 and 77; European Commission battery passport pages; Commission battery passport webinar, 7 July 2026 (survey figures as reported in trade press); VDE press release, 13 October 2026. This article is general information, not legal advice. Specific obligations depend on battery category, product design, placement and applicable exceptions