EU Drafts Harmonized Format and Technical Specifications for Battery Labeling

On December 15, 2025, the European Commission released a draft aimed at unifying the format and technical specifications for battery labels, in alignment with the implementation of the EU Battery and Waste Battery Regulation (EU) 2023/1542. The key points are as follows:

1. Harmonized Specifications for Labeling Requirements

• Label Information: All batteries must display the information specified in Annexes I, II, and III according to their category (e.g., non-rechargeable, rechargeable, industrial batteries) and follow the prescribed format guidelines.
• Label Splitting: If the battery surface lacks sufficient space, or if a single label compromises readability or safety, information may be split across multiple labels.
• Label Placement:

• • If the battery itself cannot accommodate full label information, details may be printed on the packaging or accompanying documentation, with a QR code providing digital access.
  • If packaging space is also insufficient, information must be included in accompanying documents and accessible via QR code.
• Special Battery Types:
  • Button Cells: Information must be printed on the packaging or accompanying documents, with a QR code for digital access.
  • Embedded Batteries (e.g., in medical devices): Information is provided via QR code, which may be placed on the instruction manual, product surface, or battery surface.
• Priority Order: When space is limited, information must be prioritized according to the sequence (I → XI) listed in the annexes.
• Manufacturing Date: If indicating the manufacturing date incurs excessive costs, it may be placed elsewhere (e.g., within the serial number), but the label must specify its location.

2. Label Design, Size, and Position

• Format Requirements: Labels should adhere to the formats specified in Part B of Annexes I, II, and III, ensuring high contrast and clarity.
• Size Restrictions:
  • Labels must cover at least 5% of the battery or packaging’s maximum printable area.
  • Icons must not exceed 2.5 cm × 2.5 cm, and font size must not exceed 25 pt.
  • Fonts must use Noto Sans or other open-source, EU-official-language-compatible typefaces.
• Label Position:
  • Labels should be placed on the most visible side of the battery and remain legible throughout its lifecycle.
  • Placement must avoid conflicts with other required markings (e.g., CE marks, safety symbols).
• Battery Packs: For batteries composed of multiple modules, the label should be affixed to the external casing, with individual modules optionally featuring QR codes.

3. Non-Rechargeable Battery Label

• Icon Requirement: Must display the "Do Not Charge" symbol (as per IEC 60086-4 standard), with a minimum size of 5 mm × 5 mm.
• Insufficient Space: If the battery surface cannot accommodate the symbol, it may be printed on the packaging or accompanying documents and provided via QR code.

4. Marking of Restricted and Hazardous Substances

• Restricted Substances: If batteries contain restricted substances (below regulatory limits) other than mercury, lead, or cadmium, their chemical names must be indicated.
• Hazardous Substances: If batteries contain substances classified as hazardous, their chemical names must also be marked on the label.
• Labeling Standards: Chemical names must comply with Article 18 of the CLP Regulation (EC 1272/2008) and follow the format requirements in Annexes I, II, and III.

5. Priority Order for Marking and Labeling Requirements

When battery surface space is insufficient to display all required information, the following priority order applies:

1. QR code (for digital labeling)
2. Separate recycling symbol (crossed-out wheeled bin)
3. Heavy metal symbols (mercury, cadmium, lead)
4. Non-rechargeable label
5. General information label (capacity, chemical composition, etc.)

6. Languages and Accessibility

• Language Requirements: Label information must be in a language easily understood by consumers in the target member state.
• Multilingual Handling:
  • If multiple languages are needed, the physical label may use one language, with other versions provided via QR code.
  • If member state laws explicitly require multilingual labeling, compliance is mandatory.
• Accessibility Requirements: Consumer-facing information must meet the EU Accessibility Directive (2019/882) to ensure access for persons with disabilities.

7. Carbon Footprint Label

• Uniform Format: Batteries requiring a carbon footprint performance class (e.g., EV batteries, industrial batteries >2 kWh, LMT batteries) must use the uniform carbon footprint label format specified in Annex V.
• Label Placement: The carbon footprint label must be affixed to the battery and simultaneously uploaded to the public section of the battery passport (per Regulation EU 2023/1542, Annex XIII).

The draft is currently open for public feedback, with submissions accepted until January 12, 2026. It is expected to be formally adopted by the European Commission in the second quarter of 2026 and published in the Official Journal of the European Union.

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