EU Releases Draft Act on Battery Labelling – Information Must Comply with European Accessibility Act
The European Commission has released a draft implementing regulation, Ares(2025)11169592, providing detailed technical specifications for the labelling of batteries under Regulation (EU) 2023/1542. Currently in the draft stage, this act signals a significant shift in compliance for manufacturers, specifically regarding Article 6, which mandates that all battery labelling information addressed to consumers must be accessible to persons with disabilities.
Core Requirements of Article 6: Languages and Accessibility
According to the draft regulation, battery manufacturers must ensure that their products meet the following accessibility and linguistic standards:
- Mandatory Compliance with Directive 2019/882: The draft explicitly states that labelling information addressed to consumers must align with the accessibility requirements set out in Directive (EU) 2019/882 (the European Accessibility Act or EAA).
- Multilingual Support via QR Codes: To avoid overcrowding physical labels, manufacturers may provide information in a single language, provided that digital versions in other languages are accessible via a QR code.
- Standardized Digital Accessibility: Any digital information provided (e.g., through the QR code link) must follow the four principles of accessibility: perceivability, operability, understandability, and robustness.
Technical Design Specifications
The draft act provides strict specifications for label design to ensure they can be perceived by all users, including those with visual impairments:
- Font and Typeface: The regulation recommends the use of Noto Sans or any other open-source font that is compatible with all official EU languages.
- Readability and Contrast: The text and graphic icons must be displayed in high contrast to their background to ensure they are readable.
- Accessibility Standards: Manufacturers are encouraged to utilize EN 301 549, the harmonized European standard for ICT accessibility, which provides testable criteria for digital content and interfaces.
What Manufacturers Need to Do
The implementation of these rules means that manufacturers can no longer rely solely on traditional physical labels. They must now ensure that:
- Digital content linked to battery QR codes is compatible with assistive technologies such as screen readers.
- Physical labels meet minimum size and contrast requirements for users with limited vision.
- Non-visual access is provided for essential information, ensuring that users without vision can identify and operate necessary battery functions.
Exporters to the EU market should immediately review their labelling designs and digital landing pages to ensure compliance with the EAA requirements referenced in Article 6(3). Failure to meet these standards may lead to market restrictions or withdrawal of products from the Union market.
For further details on technical specs and the EN 301 549 standard, please consult the official European Union Law portal or Victronic Technology Corporation.