Reg. (EU) 2023/1542 Art. 13(6): QR code carrier required · Art. 77 passport from 18 Feb 2027 · Art. 77(7): passport duties continue into second life.
For EU battery passports this is not either/or: Article 13(6) mandates a QR code on the battery, so every compliant battery carries one. The real question is whether a printed label alone can keep a battery identifiable and its record trustworthy through 15 years of heat, grime, swaps, repurposing and resale — the exact lifespan over which Article 77(7) keeps the passport obligation alive. That is the gap chip-bound identity closes, with the QR as the compliant front door.
A printed QR satisfies Article 13(6), resolves to the passport, and works for a showroom scan, a customs check on clean new inventory, and a consumer looking up specs. If your battery will live indoors, never change hands, and never be repurposed, the label may carry you.
A printed label is the first thing a battery loses — abrasion, heat, repaint, re-housing at a second-life converter. A chip bound to the pack keeps identity machine-verifiable through swaps and repurposing, feeds custody events to the same passport the QR resolves to, and makes a cloned label detectable instead of invisible.
| Criterion | QR / printed 2D code | NFC chip (Aeroz) |
|---|---|---|
| Satisfies Art 13(6) carrier mandate | Yes — the QR is the mandated carrier | Complements it — the QR stays on; the chip binds identity behind it |
| Survives abrasion, heat, outdoor duty | Fades and delaminates with the label | Chip embedded at pack level; readable through grime and housings |
| Second-life re-housing (Art 77(7)) | Original label usually destroyed with casing | Identity travels with the pack into the new product's passport |
| Clone resistance | A photographed code scans identically everywhere | Cryptographic challenge per tap; duplicates surface in the event log |
| Fleet swap operations | Manual scan, line of sight, one at a time | Tap or bulk read; every swap appends a custody event |
| Cost per battery | Printed with the label — near zero | Cents per pack against a 15-year, passport-bearing asset |
The regulation fixed the front door: a QR on every battery. It did not fix how you keep the record behind that door true for fifteen years. Treat the QR as the resolver and the chip as the anchor, and both mandates — the carrier and the passport's ongoing accuracy — are covered by one architecture.
Labels and information are provided via QR code — this is the carrier the regulation names. Any battery passport architecture starts from a printed QR that resolves to the record.
From 18 February 2027, EV, LMT and >2 kWh industrial batteries placed on the EU market need a passport with identification, composition, performance and durability data — the record must stay accurate, not just exist at sale.
Repurposed batteries carry the obligation forward — the entity placing a repurposed battery on the market takes over passport duties. Identity that dies with the original casing breaks this chain.
Nothing in the regulation forgives a passport that can no longer be linked to its physical battery. Carrier durability is a compliance property, not a logistics preference.
No. Article 13(6) mandates a QR code as the carrier. NFC is not required — it is how operators keep the battery-to-passport link verifiable across a service life the printed label rarely survives.
At the moment of placing on the market, yes. The risk is downstream: a battery whose label is gone or cloned still carries passport obligations, and re-establishing identity after the fact is expensive and often impossible.
Both resolve to the same passport record via GS1 Digital Link. The QR serves the human and the regulator; the chip serves automation, swap logistics and authentication — one record, two doors.
Under Article 77(7) the repurposer takes over passport duties. Chip-bound identity survives re-housing, so the new passport inherits a verified history instead of starting from an unverifiable core.
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