The short answer
For batteries covered by the EU battery-passport obligation, yes: each physical battery needs its own battery-passport identity and a unique identifier that its QR code resolves to.
That does not mean every passport must contain a completely different copy of every data field. A manufacturer can maintain shared model data, relate units to a batch, and attach the individual battery's identifier and lifecycle data to the right record. The important rule is that Battery A must not resolve to the same battery-passport identity as Battery B.
There is also an important scope distinction. From 18 February 2027, every battery must carry a QR code, but only the following batteries must have a battery passport under Article 77 of Regulation (EU) 2023/1542:
- every light means of transport battery, such as a battery for an e-bike, e-moped or e-scooter;
- every industrial battery with a capacity greater than 2 kWh; and
- every electric vehicle battery.
For other batteries, the QR code provides access to other information required by the Batteries Regulation. It is not automatically a battery passport.
This distinction matters for production planning, labeling, serialization and the choice of a digital product passport platform.
What the EU law actually requires
Article 77(1) says that from 18 February 2027 each in-scope battery placed on the market or put into service must have an electronic record called a battery passport. Article 77(2) then requires two kinds of content in that record:
- information relating to the battery model; and
- information specific to the individual battery, including information resulting from its use.
Article 77(3) connects that record to the physical battery. The passport must be accessible through the QR code required by Article 13(6), and that QR code must link to a unique identifier attributed to the battery by the economic operator placing it on the market. The Regulation defines a unique identifier as a unique character string for identifying batteries that also enables a web link to the battery passport.
In practical terms, the minimum design relationship looks like this:
Physical battery
-> QR code
-> unique battery identifier
-> that battery's passport record
-> model data + individual lifecycle data
The legal text does not say that each printed QR graphic must look visually different from every other QR graphic. A QR code can look like a normal QR code while encoding a different destination. The compliance question is whether each covered battery is connected to the correct unique identifier and record, not whether a person can tell two QR images apart by eye.
Shared model data does not remove individual battery identity
A battery manufacturer may produce thousands of units with the same model identifier, chemistry, rated capacity and expected lifetime. Those facts can be maintained once as model-level data and referenced by each individual passport record.
The unit-specific layer is what makes the passport useful as a digital serial-number record. It can include, subject to the applicable access rights:
| Layer | Typical content | Can it be shared? |
|---|---|---|
| Model | Chemistry, rated capacity, voltage, expected lifetime, carbon footprint, conformity data | Yes, across units of the same model where the data is applicable |
| Batch | Production run, manufacturing context or quality grouping | Often useful as a relationship; the exact battery-passport batch design is an implementation choice unless a specific rule requires it |
| Individual battery | Unique identifier, initial performance values, state of health, status, cycles, accidents, operating conditions and state of charge | No. This record must belong to the identified battery |
Annex XIII makes the distinction explicit. Points 1 to 3 describe information relating to the battery model. Point 4 requires information and data relating to an individual battery, including performance and durability values, state of health, status and data resulting from use.
This is why a single QR code printed on a pallet, product family or public model page is not an adequate substitute for the QR-linked identity of each covered battery. It may display useful general information, but it cannot identify the correct unit or receive that unit's later lifecycle updates.
For a deeper explanation of the model, batch and individual layers, see Battery Passport Data Model: Model, Batch and Individual Battery Data.
Does every battery need a different QR code?
In-scope batteries: plan for one unique destination per battery
For each LMT battery, industrial battery above 2 kWh and EV battery placed on the EU market or put into service, the safe and legally aligned implementation is:
- generate or assign one unique battery identifier;
- create the corresponding individual passport record;
- encode a QR code that resolves to that identifier;
- print or engrave the code on the battery, unless the placement exception applies; and
- keep the individual record accurate and up to date.
Do not copy one production unit's QR destination onto every unit in the run. That would cause multiple physical batteries to resolve to one identity and would make individual data such as state of health and cycle history ambiguous.
Batteries outside Article 77: do not overgeneralise
Article 13(6) requires a QR code on all batteries from 18 February 2027. For LMT, qualifying industrial and EV batteries, it provides access to the battery passport. For other batteries, it provides access to the applicable labeling information, the EU declaration of conformity, specified waste-management information and, for SLI batteries, certain recovered-material information.
The law therefore creates two related but different questions:
- Does this battery need a battery passport? Check Article 77(1).
- Does this battery need a QR code? From 18 February 2027, Article 13(6) says yes, subject to the marking and placement rules in Article 13(7).
Manufacturers should not use the broader QR-code deadline as shorthand for saying that every small portable battery needs an Article 77 passport.
Where can the QR code be placed?
Article 13(7) sets the default and the exception:
- the QR code must be printed or engraved visibly, legibly and indelibly on the battery; but
- where that is not possible or is not warranted because of the battery's nature and size, it may be affixed to the packaging and to documents accompanying the battery.
Annex VI, Part C adds that the code must have high contrast and be readable by a commonly available QR reader, such as one integrated into a handheld device.
The practical consequence is not “print one code on every individual battery at any cost.” The practical consequence is “make the unique battery destination physically accessible through the permitted carrier location.” For a very small or unusually shaped battery, the packaging or accompanying documents may be the correct location. Record the rationale and validate that the code remains available to the people who need it.
The Commission is also empowered to adopt delegated acts for alternative smart labels in the future. Until such a change applies, manufacturers should design around the QR-code rules in Article 13.
Who is responsible for creating the identity?
Article 77(3) places attribution of the unique identifier on the economic operator placing the battery on the market. Article 77(4) makes that operator responsible for ensuring that the passport information is accurate, complete and up to date. Written authorisation can allow another operator to act on its behalf, but the responsibility still needs an accountable owner.
The European Commission's battery-passport guidance describes the obligation as belonging to the operator placing the finished battery on the EU market, rather than suppliers of individual components or modules. Cells or modules sold for end use without further incorporation are treated as batteries under Article 1(4), so their own category and obligations must be assessed.
Before selecting a QR-code vendor, decide who owns:
- identifier issuance and uniqueness;
- model and batch relationships;
- individual battery records;
- updates from the battery management system or service network;
- access permissions;
- registry registration; and
- long-term availability if the operator changes systems or ceases activity.
The QR image is only the visible entry point. The compliance asset is the complete identity and data lifecycle behind it.
What changes after the battery leaves the factory?
The passport is not necessarily a static product label. Annex XIII, point 4(d), covers information resulting from use, including charging and discharging cycles, negative events such as accidents, operating environmental conditions including temperature, and state of charge. Point 4 also covers state of health and the battery's status.
That does not mean the public receives a live location feed or a consumer's personal data. Access is tiered, and the Regulation restricts individual information to people with a legitimate interest. The detailed categories and permitted download, sharing and reuse are to be specified by the Commission's implementing act under Article 77(9). The passport should therefore be designed for authenticated, role-based updates rather than a public, unrestricted history page.
If the battery is prepared for reuse, prepared for repurposing, repurposed or remanufactured, Article 77(7) requires a new passport linked to the original passport or passports. Article 13(9) also requires new labels or markings showing the change of status, with that information accessible through the QR code. After recycling, the battery passport ceases to exist under Article 77(8).
A production checklist for unique QR-linked passports
Use this checklist before your first production run:
- Classify every battery by category and confirm whether Article 77 applies.
- Define what constitutes one finished battery unit in your product master data.
- Assign a persistent unique identifier to every in-scope unit.
- Keep model data separate from individual data, with explicit links between them.
- Preserve batch relationships where they help manufacturing traceability and quality investigations.
- Generate a QR destination that resolves to the individual battery identifier.
- Test the code on the actual battery, packaging or accompanying documents.
- Verify contrast, readability, durability and scan behavior after production handling.
- Register the required identifier in the EU Digital Product Passport Registry.
- Integrate lifecycle updates without changing the identity of the battery.
- Create a process for reuse, repurposing, remanufacturing and recycling events.
- Test access controls for public users, legitimate-interest operators, authorities and internal editors.
The Commission's DPP Registry is operational as of July 2026. Commission Implementing Regulation (EU) 2026/1778 requires registration at the granularity specified by the applicable Union law and supports model, batch and item relationships. Its registration identifier is generated by the Registry after validation. This Registry identifier should not be confused with the battery's product identifier encoded by the QR code.
Prepare the identity layer before you print anything
The fastest way to create QR codes is not necessarily the fastest way to become compliant. Start with scope, unit definition, identifier governance and the model-to-individual data structure. Then generate the physical carrier from the validated record.
DPPAutomate helps battery manufacturers build that workflow: map required data, connect model and individual records, manage access, register identifiers and create QR-linked passports that remain updateable throughout the battery lifecycle. Explore the DPPAutomate platform, or start with the EU Battery Passport Deadline Tracker.
Continue through the cluster
This is the battery-specific answer to the broader one DPP per product question. Before printing, align the code with the identifier hierarchy, the battery passport data model, and the bulk DPP issuance workflow.
Sources and legal references
- Regulation (EU) 2023/1542, consolidated text, Article 13, labeling, marking and QR-code requirements.
- Regulation (EU) 2023/1542, consolidated text, Article 77, battery-passport scope, data, identifier, responsibility and lifecycle.
- Regulation (EU) 2023/1542, consolidated text, Annex XIII, model-level and individual-battery data layers.
- Regulation (EU) 2024/1781, ESPR, Articles 9 to 13, common DPP requirements, identifiers and Registry.
- Commission Implementing Regulation (EU) 2026/1778, DPP Registry registration and model, batch and item granularity.
- European Commission, Digital Product Passport for Batteries, current implementation overview.
- European Commission, DPP Registry now live, 20 July 2026, current Registry status.
- European Commission, DPP FAQs, non-binding implementation explanations and identifier FAQs.
Legal note: this article is an educational implementation guide, not legal advice. Product-specific facts, delegated or implementing acts and later amendments should be checked before making a compliance decision.
