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) and recycled-content (Article 8) obligations. The supply-chain due-diligence obligation in Article 48 is not limited by battery category: from 18 August 2027 it binds "economic operators that place batteries on the market or put them into service", subject to the exemptions in Article 47. 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.
Portable battery passports cannot currently be created on the production platform: the category is hidden and creation is rejected with "This product category is not available yet". The portable category is available on staging only. Statements below about what Traceable provides for portable batteries describe the platform's staging templates.
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 specifically for industrial use
- Neither an EV, LMT, nor SLI battery — the residual exclusion
The definition combines the sealed, weight and "not designed specifically for industrial use" criteria. A sealed battery weighing 5 kg or less that is not designed specifically for industrial use 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, this is a voluntary product-information capability, not an Article 77 obligation. It is not available on the production platform today (see the note at the top of this page).
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 | "the capacity" (Annex VI, Part A, point 6); the Regulation does not set the unit |
| Hazardous substances | Mandatory | "the hazardous substances present in the battery, other than mercury, cadmium or lead" (Annex VI, Part A, point 8) |
| 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 (Article 13(6) and Annex VI, Part C) | Mandatory from 18 February 2027 | No Article 77 battery passport applies; under Article 13(6), point (b), the QR code gives access to the applicable information referred to in Article 13(1) to (5), the EU declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and the information on the prevention and management of waste batteries in Article 74(1), points (a) to (f) |
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 |
| 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 | Applies through Article 48 due diligence, subject to Article 47: the supply-chain documentation includes "the country of origin of the raw material" (Article 49(2), point (c)) |
Capacity Marking
Article 13(2) of the regulation requires that, from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest, rechargeable portable batteries "shall bear a label containing information on their capacity"; non-rechargeable portable batteries instead bear a label on their minimum average duration and a "non-rechargeable" label (Article 13(3)).
For portable batteries, the capacity marking must appear on the physical battery (or, where this is not possible or not warranted on account of the nature and size of the battery, on the packaging and on the documents accompanying the battery, Article 13(7)). Traceable's portable battery template (staging only) 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) — which allows consumers to cross-verify capacity figures
The Regulation does not itself set the unit for the capacity label; harmonised specifications for the labelling requirements are adopted by implementing act under Article 13(10).
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.
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, but from 18 February 2027 they must carry a QR code: Article 13(6) provides that "all batteries shall be marked with a QR code as described in Part C of Annex VI". For portable batteries, the QR code gives access to the applicable information referred to in Article 13(1) to (5), the EU declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and the information on the prevention and management of waste batteries in Article 74(1), points (a) to (f) (Article 13(6), point (b)). The design guidance below is Traceable's recommendation for the page the QR code opens; it is not a requirement of the Regulation.
Because every portable battery must carry this code from 18 February 2027, 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 the page the QR code opens should be designed and populated:
Physical QR code requirements
- The QR code must be "printed or engraved visibly, legibly and indelibly on the battery"; where this is not possible or not warranted on account of the nature and size of the battery, it must be affixed to the packaging and to the documents accompanying the battery (Article 13(7))
- The QR code "shall be in high contrast to the background colour and of a size that is easily readable by a commonly available QR reader, such as those integrated in hand-held communication devices" (Annex VI, Part C). Traceable recommends durable label materials suited to the thermal and mechanical environment of the battery's typical application; this is not a requirement of the Regulation
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.
- 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: Traceable recommends WCAG 2.1 Level AA for the page; this is not a requirement of the Regulation.
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:
- 45% by 31 December 2023
- 63% by 31 December 2027
- 73% by 31 December 2030
Under Article 59(3), producers of portable batteries or, where appointed in accordance with Article 57(1), producer responsibility organisations "shall attain, and maintain durably" these targets. Portable batteries have no Article 77 battery passport; producers or, where appointed in accordance with Article 57(1), producer responsibility organisations must nonetheless make available to end-users and distributors the information in Article 74(1), points (a) to (f), "as a minimum at the point of sale in a visible manner and through online platforms" (Article 74(1), second subparagraph, point (a)). From 18 February 2027 the QR code must also provide access to that information (Article 13(6), point (b)). It includes:
- "the separate collection, take-back and collection points, preparation for re-use, preparation for repurposing and treatment available for waste batteries" (Article 74(1), point (c))
- "the role of end-users in contributing to the separate collection of waste batteries in accordance with their obligations under Article 64 to allow their treatment" (Article 74(1), point (b))
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. Bulk creation through the API and CSV batch import are not available for portable batteries on the production platform today, because the portable category cannot be created there. Portable battery passports cannot currently be created on the production platform: the category is hidden and creation is rejected with "This product category is not available yet". They are available on staging only.
For API documentation on bulk creation for the categories that are available, see the Developer Guide.