Portable batteries
Portable batteries are used in consumer electronics, power tools, toys, and small domestic appliances. Portable batteries have no battery-passport obligation under Article 77 of Regulation (EU) 2023/1542 — there is no Article 77 battery passport for this category at any date. Portable batteries carry the lightest regulatory data burden of any battery category: they are outside the battery-passport, carbon-footprint (Article 7), supply-chain due-diligence (Article 48) and recycled-content (Article 8) obligations. They remain subject to labelling, capacity marking, producer registration and extended-producer-responsibility rules described below.
This documentation is provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
Definition
Portable batteries are defined in Article 3(1)(9) of the regulation as batteries that are:
- Sealed — the battery does not require a user to add electrolyte or perform maintenance requiring opening the cell
- ≤5 kg — the total mass of the battery (or battery pack) is 5 kilograms or less
- Not designed for industrial purposes
- Neither an EV, LMT, nor SLI battery — the residual exclusion
The definition combines the sealed, weight and "not designed for industrial purposes" criteria. A sealed battery weighing 5 kg or less that is not designed for industrial purposes and is not an EV, LMT or SLI battery is a portable battery. A battery weighing more than 5 kg that is not classified under another category is an industrial battery.
Typical portable battery applications
| Application | Examples |
|---|---|
| Consumer electronics | Smartphones, laptops, tablets, wireless earbuds, smartwatches |
| Power tools | Cordless drills, saws, sanders, vacuum cleaners |
| Personal mobility | Power banks, portable chargers |
| Toys and leisure | Remote-controlled vehicles, electronic games, handheld gaming devices |
| Medical devices | Portable hearing aids, blood glucose monitors, portable medical equipment |
| Small domestic appliances | Robotic vacuum cleaners, electric toothbrushes, handheld blenders |
| Cameras and audio | Digital cameras, portable speakers, voice recorders |
No Battery-Passport Obligation
Portable batteries have no battery-passport (DPP) obligation under Article 77 of the Regulation. Article 77(1) sets a single battery-passport start date of 18 February 2027 that applies only to LMT batteries, industrial batteries above 2 kWh and EV batteries. Portable batteries are not in that list, so no battery passport is required for portable batteries at any date.
Dates that some sources attribute to a "portable DPP" (for example 18 August 2026) do not exist in the Regulation. Portable batteries remain subject to the labelling, capacity-marking, producer-registration and extended-producer-responsibility obligations described below.
Where an operator chooses to publish structured product information voluntarily, Traceable's batch creation and API features can support that at high volume — but this is a voluntary product-information capability, not an Article 77 obligation.
Regulatory Data Requirements
Portable batteries have no Article 77 battery passport, so the items below are not "battery-passport fields". They are the information, labelling and EPR obligations that apply to portable batteries under other provisions of the Regulation (for example labelling and capacity marking under Article 13, producer registration under Article 55, and EPR under Chapter VIII).
What Applies
| Information / label | Required? | Notes |
|---|---|---|
| Battery manufacturer and contact details | Mandatory | Full legal name and address |
| Battery model identifier | Mandatory | Model/type designation |
| Battery serial or batch number | Mandatory | Unit or batch identifier |
| Date of manufacture | Mandatory | Month and year |
| Battery category | Mandatory | "Portable" |
| Battery chemistry | Mandatory | Active materials (e.g. Li-ion NMC, Li-ion LFP, NiMH) |
| Rated capacity | Mandatory | Wh for consumer clarity; Ah at defined conditions |
| Nominal voltage | Mandatory | V |
| Hazardous substances | Mandatory | Substances above CLP threshold concentrations |
| CE marking | Mandatory | |
| Declaration of Conformity reference | Mandatory | |
| Producer registration number | Mandatory | National producer register of each Member State where the battery is placed on the market (Article 55) |
| Separate collection symbol | Mandatory | Crossed-out wheelie bin |
| EPR scheme details | Mandatory | Take-back scheme name and contact |
| QR code / battery-passport data carrier | Not applicable | No Article 77 battery passport applies to portable batteries |
What Is Not Required
| Obligation | Status for Portable Batteries |
|---|---|
| Battery passport (Article 77) | Not required — no Article 77 obligation for this category |
| Carbon footprint declaration | Not required |
| Carbon footprint performance class | Not required |
| Supply chain due diligence | Not required |
| Recycled content — cobalt, nickel, lithium | Not required (minimum thresholds do not apply) |
| Recycled content declaration (voluntary) | Permitted — operators may voluntarily declare |
| Calendar life | Not required |
| SoH methodology | Not required |
| Supply chain geographic origin | Not required |
Capacity Marking
Article 13(3)(c) of the regulation requires that portable batteries carry a capacity marking — the rated capacity of the battery expressed in a manner accessible to end consumers.
For portable batteries, the capacity marking must appear on the physical battery (or, where physically impossible due to battery size, on the packaging). Traceable's portable battery DPP includes a dedicated field for:
- Capacity in Wh (watt-hours) — the consumer-facing unit
- Capacity in mAh (milliampere-hours) — the unit typically used in consumer electronics product specifications
- Nominal voltage (V) — required to allow consumers to cross-verify capacity figures
The regulation requires the Wh figure to be marked for consumer clarity, recognising that mAh without a voltage reference is not directly comparable across products.
EU Battery Database Registration
All portable battery producers must register in the national producer register of each Member State where batteries are placed on the market (Article 55). For high-volume portable battery manufacturers with products placed on the market across multiple EU member states, registration may need to be completed in multiple national registries (or via a pan-EU collective scheme where available).
The registration must be completed before portable batteries are placed on the market. Portable batteries have no Article 77 battery passport; the producer registration number is kept in the operator's records and provided to authorities on request.
QR Code and Voluntary Product Information: Consumer-Facing Design
Portable batteries have no Article 77 battery passport, so there is no mandatory battery-passport QR code for this category. The guidance below applies where an operator chooses to publish product information voluntarily (for example via a Traceable product page and QR code) — it is not a regulatory requirement.
Where such a code is used, portable batteries are the category most likely to result in end consumers directly scanning it — whether curious about a product they are considering purchasing, troubleshooting a device, or looking for recycling information. This has practical implications for how a voluntary public product page should be designed and populated:
Physical QR code requirements
- The QR code must be permanently affixed to the battery itself or, where the battery is too small to carry a legible QR code, on the product packaging
- For batteries permanently integrated into a device (laptop battery, smartphone battery), the QR code must appear on the device packaging at minimum
- The code must remain scannable for the lifetime of the battery — use durable label materials resistant to the thermal and mechanical environment of the battery's typical application
Public DPP viewer: accessibility and readability
Because the primary user of the portable battery DPP's public access tier is a non-technical end consumer, Traceable's public DPP viewer for portable batteries should be:
- Mobile-optimised: Most consumers will scan the QR code on a smartphone. The viewer must render correctly on a mobile browser without zooming or horizontal scrolling.
- Plain language: Regulatory field names (e.g. "active cathode material") should be translated into consumer-friendly language ("battery type: lithium-ion") in the public view. Operators can use Traceable's display name customisation to achieve this.
- Action-oriented: The public DPP should prominently surface the single most important consumer actions: how to recycle the battery and what to do if the battery is damaged.
- Accessible: The DPP viewer must meet WCAG 2.1 Level AA accessibility standards. Traceable's standard viewer is built to this standard.
What consumers expect to see
When a consumer scans a portable battery QR code, they most commonly want to know:
- What is this battery? (Type, capacity, for what device)
- Is it safe? (Any hazard information, handling precautions)
- How do I recycle it? (Collection point locator, take-back scheme)
- Is this product genuine? (Manufacturer information, CE marking status)
The DPP's public access tier should answer these questions clearly and without requiring the consumer to navigate away from the page.
Extended Producer Responsibility and Collection Obligations
Portable batteries are subject to the regulation's EPR requirements. The portable category is notable for having the highest consumer collection complexity — unlike EV or industrial batteries (which are large and typically managed by professional operators), portable batteries end up in household waste if consumers are not well informed about take-back schemes.
The regulation sets portable battery collection rate targets that increase over the years:
- 51% by 31 December 2023 (transitional target from the previous Battery Directive)
- 61% by 31 December 2026
- 73% by 31 December 2030
Producers contribute to these collection targets through their EPR scheme. Portable batteries have no Article 77 battery passport; the following EPR information must nonetheless be made available to consumers (for example via labelling, packaging or a voluntary product page):
- The name and contact details of the collective take-back scheme
- Information on how end consumers can return the battery for recycling (collection point locator or at least instructions on how to find one)
High-Volume Product-Information Creation (Voluntary)
Portable batteries have no Article 77 battery-passport obligation, so there is no legal requirement to create individual passports. Where a manufacturer nonetheless chooses to publish structured product information voluntarily at scale, Traceable supports this through:
- Bulk DPP generation via API: Create thousands of DPPs programmatically using the Traceable REST API with a model template and per-unit variable fields (serial number, batch ID, manufacture date)
- CSV batch import: Upload a spreadsheet of battery units with variable fields populated, and Traceable generates individual DPPs for each row
- Model-based DPP inheritance: Define a master product model DPP with all shared fields pre-populated, and generate per-unit DPPs that inherit the model data and add only the unit-specific fields
For API documentation supporting high-volume DPP creation, see the Developer Guide.