For batteries outside the passport scope
The Article 13 QR code for batteries that need no passport
Starter (SLI), portable and small industrial batteries are outside the battery passport. They are not outside the QR code: Article 13(6) puts one on every battery from 18 February 2027, opening the information behind the label. One sealed page per model does it.
Updated 2026-10-19 · All industries · Guides to the regulation
What is in scope
The battery passport of Article 77 covers three categories: LMT batteries (e-bikes, scooters), EV batteries and industrial batteries above 2 kWh. Everything else is out: automotive starter batteries (SLI), portable batteries, and industrial batteries up to 2 kWh. For a manufacturer of starter batteries or small traction packs, that is most of the volume.
Out of the passport does not mean out of the regulation. From 18 February 2027, Article 13(6) requires a QR code on every battery that gives access to the information of Article 13: what is on the label and what sits behind it. Article 13(4) and (5) add the separate-collection symbol and, where applicable, the cadmium and lead symbols on the battery itself.
What the QR code has to open
- Label information — manufacturer, model, date of manufacture, weight, capacity, chemistry, hazardous substances and the meaning of the symbols on the battery (Article 13(1) to (5), Annex VI).
- The EU declaration of conformity for the model (Article 18).
- The battery due diligence report, where the company is in scope of Article 48 (the application date was moved by Regulation (EU) 2025/1561).
- Waste prevention and management information of Article 74(1): collection, take-back, safe handling, the meaning of the symbols.
- Recovered-material information of Article 8: whether recovered cobalt, lead, lithium or nickel is present in the active materials.
None of this is per unit. It is per model — which is why one page per model is enough, and why the page has to stay current for as long as batteries of that model are on the market.
Why a sealed page, and not a PDF on your website
A link to a PDF works until someone moves the file, re-exports the declaration of conformity, or redesigns the website. The QR code printed on a battery has to work for the life of the battery, and an authority asking in 2032 what the page said in 2027 has to get an answer. OrigoPass seals every version of the page in a signed, append-only register: the URL on the battery never changes, every change is a new dated version, and the old versions remain verifiable.
What this looks like in OrigoPass
- One product type for it — Battery, Article 13 information — with exactly the fields the article asks for, nothing from the passport that does not apply.
- One page per model: register the model once, print the QR code on every unit. A serial number per unit is optional; add it where you want traceability.
- Counts as one passport in your plan, per model. Scans are unlimited, so a model sold by the ten-thousand costs the same as one sold by the hundred.
- Your own domain and your design, the same as a passport page; the separate-collection symbol and the declaration of conformity are part of the sealed record.
- Passports next to it for the models that do need one — an LMT pack or an industrial battery above 2 kWh — in the same console, on the same domain, with the same API.
Where to start
- List your models and classify each: SLI, portable, industrial up to 2 kWh (information page) or LMT, EV, industrial above 2 kWh (passport).
- Collect per model: the label data, the declaration of conformity, the Article 74 text, the recovered-material statement.
- Register the models, print the QR codes on the label, and decide who keeps the pages current when a declaration is re-issued.
General information, not legal advice. Verify obligations for your specific products against the regulation and, where needed, with a qualified adviser.
Frequently asked
Does a car starter battery need a battery passport?
No. The passport (Article 77) covers LMT batteries, EV batteries and industrial batteries above 2 kWh. An SLI battery, a portable battery or an industrial battery up to 2 kWh needs no passport. It does need the QR code of Article 13(6) from 18 February 2027, which must give access to the information of Article 13: the label data, the EU declaration of conformity, the due diligence report where applicable, the waste information of Article 74 and the recovered-material information of Article 8.
Does the Article 13 QR code have to be unique per battery?
No. Article 13 information is model information, so one QR code and one page per model satisfy the regulation. You may still register units by serial number if you want traceability of individual batteries; the same page structure then exists per unit.
What does an Article 13 information page cost?
It counts as one passport in your plan, once per model, however many batteries carry the code and however often it is scanned. Scans are unlimited in every plan. A manufacturer with ten SLI models needs ten pages; the Starter plan covers that.