Two weeks to the 18 August battery-labelling deadline: what must be on the pack

Article 13(1) requires every battery to bear a label containing the general information listed in Part A of Annex VI from 18 August 2026 — or 18 months after the entry into force of the implementing act referred to in Article 13(10), whichever is the latest. Article 13(2) adds a capacity label for rechargeable portable, LMT and SLI batteries, and Article 13(3) requires non-rechargeable portable batteries to show their minimum average duration in specific applications plus a 'non-rechargeable' label, both on the same date.

Annex VI Part A is a closed list of ten items, so a gap check is mechanical rather than interpretive. Note what is not on it: no nominal voltage, and no durability parameters — electrochemical performance and durability live in Annexes III and IV and in the passport, not on the label.

Two markings sit outside that 2026 date. The separate-collection symbol under Article 13(4) has applied since 18 August 2025, sized at least 3 % of the largest side (1,5 % for cylindrical cells), capped at 5 × 5 cm, and moved to the packaging at a minimum 1 × 1 cm where the battery is too small. And under Article 13(5), batteries containing more than 0,002 % cadmium or more than 0,004 % lead must carry Cd or Pb beneath that symbol, at a quarter of its size.

• Manufacturer identification, battery category and battery identification, place of manufacture, and date of manufacture (month and year).
• Weight, capacity and chemistry.
• Hazardous substances present other than mercury, cadmium and lead, and the usable extinguishing agent.
• Critical raw materials present in a concentration above 0,1 % weight by weight.
• Separate-collection symbol (since 18 August 2025), plus Cd or Pb where the cadmium or lead thresholds are exceeded.

Nothing in Article 13 is technically difficult. What breaks programmes is that a label change is a packaging change: artwork revision, regulatory sign-off, plate or digital-print setup, a converter slot, and then the sell-through of existing stock. For most consumer and industrial packaging that chain runs eight to sixteen weeks even when nobody argues about wording, and converters do not hold capacity open for a compliance date they have not been told about.

That is why the operative deadline for your team is not 18 August. It is the artwork-freeze date you work backwards to from it: the last day a change can enter the print chain and still appear on packs leaving your line before batteries reach the market. Teams that discovered this in July are now negotiating for converter slots at a premium, or relabelling by hand.

The other lead-time trap is stock in transit and in distributor warehouses. Decide now, in writing, how you treat batteries already placed on the market versus those still to be placed, because the answer determines whether you need an over-label programme at all.

Manufacturers own the label content and its durability: it must survive the product's life, which rules out some in-line inkjet solutions on cells that see heat or abrasion. Importers carry the harder position — they must verify that a label produced by a manufacturer outside the EU actually says what Article 13 requires, in the language of the market they are placing it on, and they cannot fix a wrong label after the fact without a relabelling operation of their own.

Certifiers and testing bodies get pulled in earlier than most teams expect, because capacity and minimum-average-duration claims on the label have to be traceable to test data, not to a datasheet inherited from a supplier. Article 13 is also one of the requirements a Module A conformity assessment covers, and Annex VIII expressly requires a specimen of the Article 13 label in the technical documentation. If a value on the pack cannot be tied to a test report, it is an enforcement finding waiting for the first market-surveillance check.

• Manufacturers: freeze artwork, prove the label is visible, legible and indelible, keep the test evidence behind every declared value.
• Importers: verify the incoming label against Article 13 and Annex VI Part A before the shipment is booked, not on arrival, and hold a relabelling contingency.
• Certifiers and labs: expect capacity and minimum-average-duration values to be traced back to test reports, and a label specimen in the technical file.

These are three separate obligations on two dates, and conflating them is the most common planning error we see. The general labelling under Article 13 applies from 18 August 2026. The QR code required by Article 13(6) applies from 18 February 2027, and the battery passport under Article 77 applies from the same date — 18 February 2027.

So the August date is a printing and artwork problem, and February 2027 is a data problem: the QR code is meaningless without the passport data set behind it, and that data mostly sits with suppliers. Treat them as one programme with two very different critical paths, and read our issue on the battery passport as a data-ownership problem for the second half.