Regulatory Alert: EU Releases Technical Draft on Battery Labelling – Detailed Requirements for Consumer Info and Placement
The European Commission has published a draft implementing regulation, Ares(2025)11169592, establishing unified formats and technical specifications for the labelling of batteries under Regulation (EU) 2023/1542. This draft act provides a clear roadmap for manufacturers regarding what information must be disclosed to consumers and exactly where these labels must be positioned on the product to ensure maximum visibility and durability.
I. Mandatory Information Addressed to Consumers
According to the draft act and its various Annexes, manufacturers must include the following essential elements on their labels, tailored to the battery category (e.g., portable, SLI, EV, or industrial):
- Manufacturer & Product ID: Includes the manufacturer’s name, registered trademark, contact address (including website and email), and the battery category, model, batch, or serial number.
- Manufacturing Details: The label must specify the date of manufacture (month and year) and the precise location of manufacture (town, region, and country).
- Technical Characteristics:
- Electrochemical Composition: Must be indicated using standard nomenclature (e.g., Pb, Li-ion, Ni-MH).
- Capacity & Performance: Rechargeable batteries must show capacity in mAh or Ah; non-rechargeable portable batteries must display "minimum average duration" for specific applications.
- Safety & Environmental Info: This includes symbols for separate collection, indications of hazardous substances or critical raw materials (>0.1%), and information on suitable extinguishing agents.
- Carbon Footprint (Specific Categories): Batteries such as those for electric vehicles must feature a carbon footprint performance class (A–E) and the total life-cycle CO2 value.
II. Label Placement and Visibility Standards: "Visible and Durable"
The draft regulation introduces strict rules for the physical presentation of labels (Article 2) to ensure they are accessible and long-lasting:
- Preferred Location: Labels must be placed on the side of the battery that is most visible during its intended use.
- Surface Area Requirement: The label must cover at least 5% of the largest printable or engravable surface area of the battery or its packaging.
- Durability: The design must ensure that all text and icons remain readable until the end of the battery's service life.
- Font and Contrast: Text and icons must be in high contrast to the background, utilizing the Noto Sans font or another open-source font compatible with all official EU languages.
- Specific Handling for Hidden Batteries: For batteries incorporated into products or vehicles where they are not immediately visible, the QR code must be visible on the battery surface, in the accompanying documentation, and on the exterior of the product (accompanied by a battery icon).
- Battery Packs: For assemblies with multiple modules, the label must be affixed to the external housing.
III. The Accessibility and Digital Intersection
Crucially, Article 6 of the draft act mandates that all labelling information addressed to consumers must comply with the accessibility requirements of Directive (EU) 2019/882 (European Accessibility Act).
Manufacturers are encouraged to use QR codes as a digital solution to provide translations or detailed documentation. This avoids overcrowding physical labels while ensuring that information remains perceivable and operable for persons with disabilities, aligned with technical standards like EN 301 549.
Compliance Timeline for Exporters
Exporters to the EU must immediately review their current label layouts and physical placement strategies. As the draft act moves toward adoption, ensuring that labels are "visible during use" and that digital landing pages (linked via QR codes) are fully accessible will be critical for passing conformity assessments. Failure to comply may result in products being restricted or withdrawn from the Union market.
For the full technical specifications and Annexes, please refer to the official EUR-Lex portal or contact Victronic Technology Corporation.