The battery deadline that never moved: what is really locked for 18 February 2027

Two different regimes sit inside Article 13 of Regulation (EU) 2023/1542, and only one of them has a soft trigger. The general-information label and the capacity label (Article 13(1)–(3), Annex VI Part A) apply from "18 August 2026 or 18 months after the Article 13(10) implementing act enters into force, whichever is the latest." That act was released only in draft in December 2025, so the physical-label clock has not started on the trade press's assumed date.

The QR code obligation (Article 13(6)) and the battery passport (Article 77) carry no such clause. Both apply from 18 February 2027 as a fixed calendar date — no implementing-act dependency, no postponement provision in the text. If you read one thing from this issue, read that: the delay story is about printed labels, not about the digital layer.

• Soft (moved): general-information and capacity labels — Art 13(1)–(3), tied to the Art 13(10) implementing act.
• Fixed: QR code on every battery — Art 13(6), 18 February 2027.
• Fixed: digital battery passport — Art 77, 18 February 2027.

Every battery placed on the EU market must carry a QR code from 18 February 2027 — portable, LMT, industrial and EV alike. The QR code is the universal access key: scanning it takes the user to the information the regulation assigns to that battery category.

The full digital battery passport sits behind that QR code only for three categories: LMT batteries (e-bikes, e-scooters), industrial batteries with a capacity above 2 kWh, and electric-vehicle batteries. For everything else — portable batteries, industrial batteries at or below 2 kWh — the QR code links to the label and conformity information instead of a full passport record.

The practical consequence: you cannot scope your February 2027 work by product line without this split. A manufacturer shipping both portable and EV batteries runs a QR-code programme for all of them and a passport programme for the EV range only.

• QR code (Art 13(6)): all battery categories, from 18 February 2027.
• Battery passport (Art 77): LMT batteries, industrial batteries >2 kWh, EV batteries.
• Portable and small industrial batteries: QR code links to label/conformity data, not a passport.

Manufacturers should treat the label delay as artwork breathing room, not as programme relief. The February 2027 deliverables are data deliverables: QR-code generation at battery-model level, a resolution service that stays live for the battery's life, and — for the three passport categories — a populated passport record with performance, durability and carbon-footprint attributes. None of that gets easier because a printed label slipped.

Importers hold the same fixed dates for products they did not manufacture. From 18 February 2027 the battery you place on the EU market must carry the QR code and, where applicable, the passport — and market-surveillance authorities will scan first and ask questions second. Contract now for QR-code and passport data from your non-EU suppliers, and verify what the codes resolve to before stock ships.

Certifiers and notified bodies should expect February 2027 to arrive on schedule regardless of the labelling confusion. The conformity-assessment work around passport data does not pause while Article 13(10) finishes its legislative journey.

• Manufacturers: build QR generation and the resolution service now; the soft label date does not help the hard digital one.
• Importers: contract for QR-code and passport data from non-EU suppliers, and test what codes resolve to pre-shipment.
• Certifiers: February 2027 passport conformity work proceeds on the fixed date.

Anchor the programme to the fixed dates. 18 February 2027 is the spine: QR code for everything, passport for the three categories, separate-collection symbol already in force since 18 August 2025. Work backwards from February — data sourcing, QR infrastructure and testing all have to finish before that date.

Treat the physical-label date as a tracking item with a trigger, not a deadline. When the Article 13(10) act is adopted and enters into force, the 18-month clock starts; prepare label artwork and templates now so adoption is a production task, not a redesign. Issues 015 and 017 track the implementing act's progress.

• Backwards-plan from 18 February 2027 for QR and passport delivery.
• Keep physical-label artwork ready to finalise when the Art 13(10) act enters into force.
• Do not let the label delay reset the programme's critical path.