One finished-product SKU may contain a cell, a battery pack, a charger, a radio module and several market versions. The useful starting point is not a universal “battery passport” template. It is a category and role assessment that connects the physical product, its documents, its labels and its public wording to the same SKU record.
This article is based on Regulation (EU) 2023/1542 and the current consolidated EUR-Lex text, reviewed on 21 August 2026. The Regulation replaced Directive 2006/66/EC, but its obligations apply on different dates and with different category boundaries. This is a documentation guide, not legal advice and not a promise of certification, marketplace treatment or regulatory outcome.
Three corrections before building the workbook
- The regulation should be identified as Regulation (EU) 2023/1542, not “Regulation (EU) 2026/100”. Unverified dates, pilot percentages and invented enforcement data should not be placed on a product page.
- A battery passport does not apply to every battery on the same date. Article 77 requires an electronic battery passport from 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries.
- A QR code is not synonymous with a battery passport. Under Article 13(6), QR access is category-specific: it points to the battery passport for the covered categories and to the applicable label, declaration, Article 52(3) report and waste-management information for other batteries.
1. Establish the category and market role first
Regulation (EU) 2023/1542 covers portable batteries, starting, lighting and ignition batteries (SLI), light means of transport batteries (LMT), electric-vehicle batteries and industrial batteries. It also covers batteries incorporated into products or designed to be incorporated into products. A battery-containing product may also fall under other EU legislation. RED, EMC, LVD, RoHS and WEEE documents must be assessed by product function and legal scope; the presence of a battery does not automatically tick every box.
At minimum, the SKU register should record:
- finished-product model, seller SKU, ASIN, variation, Member States of sale and first placing-on-market date;
- battery category: portable, LMT, industrial, EV or SLI; where more than one category may apply, document the category analysis and the stricter applicable requirements;
- pack model, cell model, chemistry, rated capacity, nominal voltage, energy, batch or serial identification, and any BMS or protection-board change;
- the manufacturer, importer, authorised representative or other relevant economic operator;
- whether the model references on the physical label, packaging, instructions, listing, reports and declarations are exactly aligned.
2. Turn the SKU-to-battery relationship into readable evidence
| Review layer | Question | Evidence to retain |
|---|---|---|
| Finished product | What exactly is the consumer-facing SKU, ASIN, model and variation? | Product specification, SKU master data, listing capture and packaging photos |
| Battery identity | Which pack is installed or supplied, and can its cells, capacity and batch be traced? | BOM, datasheet, label photos, production-batch records and supplier change records |
| Legal classification | Which category applies, and which Articles and annexes are relevant? | Classification memo, intended use, rated energy and LMT/EV/industrial assessment |
| Conformity evidence | Have the applicable technical file, conformity assessment and EU declaration been prepared? | Technical-file index, assessment records, test reports, EU DoC and CE-marking basis |
| Information and labels | Do the label, QR, instructions and listing provide the information required for this category? | Member-State label versions, product photos, instructions, QR target and page revision record |
| Change control | What must be rechecked after a cell, pack, BMS, capacity or supplier change? | Change request, impact assessment, old/new model comparison and update rationale |
Do not assume that colour, bundle size or a parent-child listing makes different battery packs one model. Use the actual pack, model identification, rated parameters and document scope. When a supplier changes a cell or BMS, freeze the affected batch and check the technical file, EU DoC, label, instructions and listing against the physical product before release.
3. Separate the dates for labels, QR access and passports
| Milestone | What the text says | Workbook action |
|---|---|---|
| Label milestone around 18 August 2026 | Article 13 contains date-based requirements for general battery information and capacity information for rechargeable portable, LMT and SLI batteries. The text also includes an “18 months or 18 months after the relevant implementing act, whichever is later” condition. | Record the consolidated-text version, implementing-act status, Member-State language and physical-label revision. Do not describe this as one universal “2026 full enforcement” date. |
| QR milestone from 18 February 2027 | Article 13(6) requires QR access to the information applicable to the battery category. For passport categories, the QR leads to the passport; for other batteries, it leads to the applicable information set. | Test the QR target, completeness, accuracy and freshness, and link its data version to the label and battery model. |
| Battery passport from 18 February 2027 | LMT, industrial batteries above 2 kWh and EV batteries require an electronic battery passport. Article 77 uses access rights and requires interoperable, machine-readable and searchable information. | Prepare passport data by battery model and individual battery where applicable. Separate public, authority and legitimate-interest access; do not call a supplier PDF or self-hosted page a completed passport. |
The important control is not a decorative QR. It is the accuracy, completeness and update responsibility for the data behind it. Record the data source, owner, date, access rights and change reason so that a later supplier change can be explained.
4. Keep technical documentation, EU DoC and CE analysis distinct
Before placing a battery on the market, the manufacturer should prepare technical documentation under the applicable requirements in Annex VIII and complete the relevant conformity-assessment procedure. Article 18 requires the EU declaration of conformity to remain up to date and identify the Union acts concerned. Articles 19 and 20 govern the CE-marking principles and conditions when the applicable assessment has been completed. The Batteries Regulation does not turn RED, LVD or FCC into universal battery documents.
- Wireless functions may bring RED into scope. EMC, low-voltage, chemical-substance and WEEE obligations must be assessed against the product and the applicable act.
- A test report must correspond to the real battery category, model, sample and version. A familiar standard name does not by itself prove every requirement in the Batteries Regulation.
- Manufacturers must retain the technical documentation and EU DoC under the applicable retention rules. Do not rewrite the law as a fixed “12 documents per ASIN and 48 hours for every EU RP” rule.
- Importers have their own checks before placing a battery on the market, including the DoC, technical documentation, assessment procedure, CE marking, labelling and instructions. Record the checker, evidence and disposition of any gap.
5. Do not generalise carbon, recycled-content or due-diligence rules
The Regulation sets different carbon-footprint, recycled-content, performance and labelling steps for EV batteries, LMT batteries, industrial batteries above 2 kWh and other categories. Use the category and date analysis under Articles 7 and 8 and the relevant annexes. Do not turn one category’s requirement into a universal threshold for every power bank, coin cell or ordinary portable battery.
Chapter VII on battery raw-material due diligence also has a defined scope, economic-operator threshold and exclusions. For an operator within scope, Articles 47–52 call for a policy, supply-chain controls, risk identification, mitigation, third-party verification and reporting records. A business outside that chapter is not thereby exempt from other safety, labelling or producer-responsibility duties.
6. Six-step manual review checklist
- Lock one SKU: place the listing, packaging, instructions, physical sample, BOM and supplier files in one record.
- Confirm category and timing: cite the relevant Article, annex and consolidated-text version.
- Compare identifiers: finished-product, pack and cell models, batch and capacity must lead back to the sample, not only to a document title.
- Review conformity evidence: decide which tests, technical files, EU DoC, CE, instructions and other product-law documents actually apply.
- Review labels and QR: check Member-State language, required information, target and update owner; prepare a separate passport data sheet where Article 77 applies.
- Close the change loop: after a cell, BMS, packaging, page or market change, record the impact, reviewer, updated documents and release basis.
绿色方舟（深圳）认证有限公司 recommends separating “verified”, “pending supplier confirmation” and “not applicable with reason” in the register. That prevents a marketing sentence, marketplace prompt or single test report from being mistaken for a complete legal conclusion. Public wording should stay within the evidence that is currently supported.
Sources and boundaries
- Regulation (EU) 2023/1542 consolidated text: categories, labels, QR access, EU DoC, economic operators, due diligence and the battery passport.
- European Commission guidance on removability and replaceability: practical guidance on Article 11.
Product-specific review still depends on the Member States of sale, product function, supply-chain role and the latest legal text. This article makes no promise about approval, certification, customs clearance, delisting recovery, ranking or sales.
