- Short answer
- Yes, if you make, import or distribute batteries for the EU, even inside products: every battery needs a QR code from 18 February 2027.
- Your own brand on it
- You count as the manufacturer (Article 44) and must ensure the battery is marked.
- Reselling or importing, not under your brand
- You verify the CE marking and Article 13 labelling before selling (Articles 41 and 42).
- Battery passport
- From 18 February 2027: LMT, industrial above 2 kWh and electric vehicle batteries; others' QR code opens required information.
- Already on the label
- The separate collection symbol, marked on all batteries since 18 August 2025, or on the packaging for very small ones.
- What Shopify gives you
- A Disclosures metafield for warnings; no QR or passport feature on the Shopify pages we read, 13 September 2026.
Are you the manufacturer, importer or distributor?
Regulation (EU) 2023/1542 hangs its duties on your place in the supply chain, and online selling sits inside it: an economic operator covers placing batteries on the market or making them available, “including online”.
The Regulation also applies to batteries “incorporated into or added to products”, so a battery inside a product you sell is in scope.
Which role you hold, and your marking duty
| If you | The Regulation calls you | Your marking duty |
|---|---|---|
| Make a battery, or have one made, and market it under your own name or trademark | Manufacturer | Ensure it is marked and labelled under Article 13 (Article 38) |
| Import or resell a battery under your own name or trademark | Manufacturer (Article 44) | Take on the manufacturer's obligations under Article 38 |
| Are established in the EU and place a battery from a third country on the market | Importer | Verify its CE marking and Article 13 labelling before placing it on the market (Article 41) |
| Make a battery available in the supply chain as neither its manufacturer nor its importer | Distributor | Verify its CE marking and Article 13 labelling before making it available (Article 42) |
Regulation (EU) 2023/1542, Articles 3, 38, 41, 42 and 44, read 13 September 2026.
Article 44 is the private-label row: an importer or distributor is considered a manufacturer where a battery is placed on the market under its own name or trademark, where it modifies a battery already on the market in a way that could affect compliance, or where it changes the purpose of such a battery. The importer row means an EU-established business; the role of a non-EU store shipping straight to EU customers is outside this page.
What must the QR code lead to for your battery?
Article 13(6) sets the rule in one line: “From 18 February 2027, all batteries shall be marked with a QR code”. What the code opens depends on the battery's category:
- LMT batteries (Article 3: “sealed, weighs 25 kg or less”, for “the traction of wheeled vehicles”), industrial batteries above 2 kWh and electric vehicle batteries: the battery passport under Article 77.
- Other batteries: the information in Article 13(1) to (5), the declaration of conformity, the report under Article 52(3) and information on preventing and managing waste batteries.
- SLI (starting, lighting and ignition) batteries also: the amount of cobalt, lead, lithium or nickel recovered from waste and present in their active materials.
The QR code and labels are printed or engraved on the battery itself. Where that is not possible, or not warranted by the battery's nature and size, they go on the packaging and on the documents accompanying the battery.
Does Shopify add the QR code or battery passport?
None of the Shopify Help Center, shopify.dev, changelog.shopify.com, Markets or Plus pages we read on 13 September 2026 describes a battery QR-code or battery-passport feature.
What Shopify documents is general. Its consumer protection page lists “CE product marking in the European Union” and “battery safety information” among the warnings you can add to product pages through the Disclosures product metafield and metaobject entries — here is where those fields live in your admin.
If you sell cross-border through Managed Markets, a separate rule covers that feature only: its prohibited items list says “All batteries, electronics, and electrical items that contain or have batteries attached, or plug directly into the electrical current, are restricted.”
Which dates apply to the label and QR code?
The labelling duties arrive in steps under Articles 13, 77 and 96; the QR code and the battery passport are still ahead as of September 2026.
Battery Regulation dates
| Date | What applies | Status, September 2026 |
|---|---|---|
| 18 February 2024 | The Regulation, except where its provisions set other dates | Applies |
| 18 August 2024 | Chapter VI obligations of economic operators, Articles 38 to 46 | Applies |
| 18 August 2025 | All batteries marked with the separate collection symbol | Applies |
| 18 August 2026 or 18 months after the implementing act's entry into force, whichever is the latest | A label with the general information in Part A of Annex VI | Depends on the implementing act |
| 18 February 2027 | All batteries marked with a QR code; a battery passport for LMT, industrial above 2 kWh and electric vehicle batteries placed on the market or put into service | Not yet |
Regulation (EU) 2023/1542, Articles 13, 77 and 96, read 13 September 2026.
Whether batteries placed on the market before 18 February 2027 need the code is not settled on this page.
For LMT, industrial above 2 kWh and electric vehicle batteries, the passport “shall be accessible through the QR code referred to in Article 13(6) which links to a unique identifier that the economic operator placing the battery on the market shall attribute to it”.
To prepare, take the duty in your row of the role table — ensure or verify the Article 13 labelling — and read it against Article 13(6), where the QR requirement sits.
This article was written entirely by AI under human editorial direction. The editor sets the topic and structure, runs multi-stage validation on facts, links, and interactive elements, and verifies the output is useful from a business perspective. All claims are checked against official Shopify sources. Details may change — always confirm critical data at shopify.com.
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