(EU) 2023/1542 · Annex XIII(1)(q)
Battery marking: one deadline has already passed, another is not yet fixed
Article 13 is the most underestimated article in the regulation, because a single article carries three different kinds of deadline: one absolute date that has already passed, three conditional ones tied to a Commission act, and one tied to the passport. Read it quickly and you see one year — and miss the one that arrived last year.
Paragraph 4: an absolute deadline that passed in August 2025
From 18 August 2025, all batteries must be marked with the separate collection symbol shown in Part B of Annex VI. This provision carries no conditionality on an implementing act and no transitional period. Anyone who has placed a battery on the market since then without that symbol is behind — regardless of what happens with the passport deadline.
Paragraphs 1 to 3: conditional deadlines tied to a Commission act
The general label under Part A of Annex VI, the capacity label for rechargeable portable, LMT and SLI batteries, and the minimum average duration label for non-rechargeable portable batteries all start on 18 August 2026 or eighteen months after the implementing act referred to in paragraph 10 enters into force, whichever is the latest. The Commission was to adopt that act by 18 August 2025; whether it has been adopted is something we do not assert on this page, because we have not verified it at source.
Paragraph 5: the trap Annex I does not cover
All batteries containing more than 0.002% cadmium or more than 0.004% lead must be marked with the chemical symbol for the metal concerned, Cd or Pb. This provision has no date of its own. More importantly: the threshold for the lead marking is 0.004%, while Annex I permits portable batteries up to 0.01% lead. Between those two figures a battery is entirely lawful yet must still carry the Pb marking. This is precisely what companies miss, because they check only the Annex I limits.
Paragraph 7: the marking belongs on the battery itself
The labels and the QR code must be printed or engraved visibly, legibly and indelibly on the battery. Only where that is not possible or not warranted on account of the nature and size of the battery may they be affixed to the packaging and to the accompanying documents. That is a design requirement, not a printing one — with small housings it has to be considered at the design stage.
Paragraph 9: remanufactured batteries need new markings
Batteries that have been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing must bear new labels or markings under this article, containing information on their change of status in accordance with point 4 of Annex XIII. Anyone building a second-life business carries a distinct obligation here.
Where it goes wrong
- Filing all marking work under the 18 February 2027 deadline — the separate collection symbol fell due on 18 August 2025.
- Checking lead only against Annex I: between 0.004% and 0.01% the battery is lawful but must carry the Pb marking.
- Marking only the packaging when the size of the battery would allow marking on the battery itself.
- Repurposed and remanufactured batteries without new markings showing the change of status.
- Stating that the general label is due 18 August 2026 — without checking the implementing act's status it may be later.
Frequently asked
Which marking deadline has already passed?
Article 13(4): since 18 August 2025 all batteries must bear the separate collection symbol from Part B of Annex VI. That date is absolute and unconditional.
When is the general label due?
Article 13(1): 18 August 2026 or eighteen months after the implementing act under Article 13(10) enters into force, whichever is the latest. No absolute date can be stated without checking the act's status.
At what lead content is the Pb marking required?
Above 0.004% under Article 13(5). That is lower than the 0.01% limit Annex I permits for portable batteries, so it is possible to comply with Annex I and still owe the marking.
May the marking be on the packaging only?
Only where printing or engraving on the battery itself is not possible or not warranted given its nature and size. Otherwise Article 13(7) requires it on the battery.
Check whether you can prove this field
The free check runs through every mandatory field for your battery category. No sign-up.
Start the check