The EU Digital Product Passport is moving from policy to printed packaging, and batteries are first. If you make, import, or sell certain batteries into the EU, a QR code becomes a legal requirement on a fixed date. This post explains what that requirement is, who it touches, and what a QR code has to do with it — without pretending a general QR tool is a compliance product, because it is not.
Does your packaging need a QR code by 2027?
Only if you place in-scope batteries on the EU market — for those, a QR code linking to a battery passport is mandatory from 18 February 2027. This comes from the EU Battery Regulation, Regulation (EU) 2023/1542, Article 77 (reviewed July 2026). It is not a blanket rule for all packaging yet. The 2027 deadline applies specifically to the battery categories the regulation names. Most other product types are on a later, phased timeline under the broader framework. So the honest answer for most sellers is: not yet, unless you are in the battery scope.
Which products are actually in scope for 2027?
The 18 February 2027 mandate covers electric-vehicle (EV) batteries, industrial batteries above 2 kWh, and light-means-of-transport (LMT) batteries such as e-bike batteries. Small consumer cells like AA batteries and standard SLI starter batteries in petrol and diesel cars are outside the passport requirement. If you sell EV, large industrial, or e-bike batteries into the EU, you are in scope. If you sell packaged consumer goods, textiles, or electronics, you are watching the framework that batteries are piloting — not meeting a 2027 battery deadline.
What is a battery passport, and why a QR code?
A battery passport is a structured digital record of a battery’s identity and lifecycle data, and the QR code is the physical link to it. From 18 February 2027, in-scope batteries must be marked with a QR code that provides access to the passport. The code carries a unique identifier following recognised standards — the regulation points to ISO/IEC 15459 or equivalent for the identifier, and ISO/IEC 18004 for the QR symbol itself. Importantly, the passport is not a PDF or a static web page. The regulation requires the data to be based on open standards and provided in an interoperable format, with tiered access for different audiences.
What does the timeline actually look like?
The battery passport deadline sits inside a chain of phased obligations, and 2027 is the passport milestone. The dates that matter:
| Date | Obligation |
|---|---|
| 18 Feb 2024 | Amended Battery Regulation takes effect |
| 18 Feb 2025 | Carbon footprint declaration, EV batteries |
| 18 Feb 2026 | Carbon footprint declaration, industrial batteries >2 kWh |
| 18 Aug 2026 | Labelling and carbon footprint performance classes |
| 18 Feb 2027 | Full battery passport mandate (QR code required) |
One nuance worth knowing: the battery due-diligence obligations were postponed to 18 August 2027 via Regulation (EU) 2025/1561, but that postponement does not move the 18 February 2027 passport deadline itself. The two dates are often confused. The passport, and its QR code, stays on the February date.
Does the deadline apply to non-EU manufacturers?
Yes — for importers, the deadline applies at the point of placing the product on the EU market, not at the point of manufacture. A battery made before February 2027 but imported into the EU after that date still needs to comply. Market surveillance authorities begin enforcement on the compliance date, and non-compliant products can be refused entry, removed from the market, or subject to penalties. If you sell into the EU from outside it, “we manufactured it earlier” is not a defense.
What does a dynamic QR code have to do with this?
A dynamic QR code is a natural fit for a passport link because the passport data changes over the battery’s life while the printed code cannot. Lifecycle information — state of health, ownership, repair events — updates over years, and reprinting a code onto a battery already in the field is not an option. A code that encodes a stable short link, resolving to a destination you can update, matches how a passport is meant to evolve. That is a general property of dynamic codes, and it is where a tool like redireo fits: bulk-generating serialized dynamic codes (redireo supports variable-data creation up to 500 codes per request), keeping the printed identifier stable, and letting the destination change as data does.
Is redireo a DPP or GS1 compliance product?
No — redireo is a dynamic-QR and GS1 Digital Link resolver, not a Digital Product Passport or GS1 compliance solution. This is the honest boundary. redireo does now provide a GS1 Digital Link resolver on your own domain (see our regulated products and DPP solution), so it can carry a gs1:dpp link on the physical side and keep it editable. But meeting the Battery Regulation means conforming to specific data models, identifier standards, open-format and interoperability requirements, a tiered access architecture, and registering the passport identifier where the rules require it. Those are compliance obligations that sit with the manufacturer and with systems built for that standard. redireo resolves and manages the link; it does not certify, structure, or host the passport data to the regulation’s schema, and we do not claim it does. If you need DPP conformance, you need a DPP platform; redireo is the resolver component on the physical side.
The 2027 battery deadline is real, specific, and closer than it looks. If you are in scope, start with the standard and the data model, then decide how the physical QR link gets produced and kept current. A dynamic code solves the “the link must stay editable” half of the problem. It does not solve the compliance half, and no one should tell you it does.