xvEPA
White Paper Summarizing Existing Battery
Labeling Requirements and Standards
U.S. Environmental Protection Agency
Office of Resource Conservation and Recovery
January 2025
EPA 530-R-25-004
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Contents
1 Introduction 4
2 Considerations for Battery Labeling 5
3 U.S. Federal Battery Labeling Requirements 6
3.1 The Mercury-Containing and Rechargeable Battery Management Act (1996) 6
3.2 Call2Recycle Recycling Labels (1998) 6
3.3 Reese's Law (2022) 7
3.4 Transportation Labeling for Lithium-ion Batteries 7
4 State-Level Battery Labeling Requirements 8
5 International Battery Labeling Requirements 10
5.1 European Union Batteries Regulation (2023) 10
5.2 Battery Association of Japan Labeling Requirements (2000) 10
6 Voluntary Battery Labeling Standards 11
6.1 Society of Automotive Engineers International Standards 11
6.2 Battery Council International Recommended Practices Battery Labeling Manual 11
6.3 National Salvage Vehicle Reporting Program 12
6.4 Automotive Recyclers Association 12
7 Other Battery Safety and Labeling Standards 13
8 Summary of Select Battery Labeling Requirements and Guidelines 15
9 Key Findings 17
10 Next Steps 18
References 19
Appendix: Relevant Legislation 22
Relevant Text from the Mercury-Containing and Rechargeable Battery Management Act (1996) 22
Relevant Text from California AB-2440 Responsible Battery Recycling Act (2022) 23
Relevant Text from California SB-1215 Electronic Waste Recycling Act (2003) 23
Relevant Text from Washington State SB-5144—Providing for Responsible Environmental Management of
Batteries (2023) 24
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Abbreviations
ANSI
American National Standards Institute
ARA
Automotive Recyclers Association
BCI
Battery Council International
BIL
Bipartisan Infrastructure Law
Cd
cadmium
CPSC
U.S. Consumer Product Safety Commission
DOE
U.S. Department of Energy
DOT
U.S. Department of Transportation
EOL
end-of-life
EPA
U.S. Environmental Protection Agency
EPR
extended producer responsibility
EU
European Union
EV
electric vehicle
HEV
hybrid electric vehicle
IEC
International Electrotechnical Commission
ISO
International Organization for Standards
LMT
light means of transport
LIB
lithium-ion battery
NFPA
National Fire Protection Association
Ni-Cd
nickel-cadmium
NSVRP
National Salvage Vehicle Reporting Program
Pb
lead
PHEV
plug-in hybrid electric vehicles
QR
quick response
RFI
request for information
RFID
radio frequency identification
SAE
Society of Automotive Engineers
SSLA
small sealed lead-acid
SLI
starting, lighting, and ignition
UL
Underwriters Laboratories
ZEV
zero-emission vehicle
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1 Introduction
A clean energy transformation is underway. As the United States rapidly transitions away from fossil fuels,
renewable energy sources are seeing unprecedented growth. Batteries play a central role in this transformation.
They power everything from cars and trucks to electric bikes (e-bikes) and consumer electronics. They are also
used in many industrial applications, from powering construction and agricultural equipment to providing
backup power for critical infrastructure and storing energy for renewable power generation. As battery use
increases globally, so does the demand for critical materials needed to manufacture single-use and rechargeable
batteries. To reduce global reliance on the mining of virgin raw materials, including cobalt and lithium, the
United States will need to increase the recovery of these critical materials from end-of-life (EOL) batteries.
However, increasing these recovery rates will require overcoming the current technological, economic,
regulatory, and social barriers to the safe collection and recycling of batteries. Today, many batteries are
disposed of in municipal solid waste or recycling because consumers lack information on how or where to
properly manage them. Products containing embedded batteries are often disposed of in municipal solid waste
because consumers are unaware of the presence of a battery.
Sections 70401 and 40207 of the Bipartisan Infrastructure Law (BIL) direct the U.S. Environmental Protection
Agency (EPA) to address these challenges along the battery life cycle through the development of voluntary
battery labeling guidelines, battery collection best practices, consumer education materials, and a national
extended producer responsibility (EPR) framework for batteries drafted in close coordination with the U.S.
Department of Energy (DOE).1 Together, these efforts will help state, local, and Tribal governments establish and
improve battery collection programs and help consumers more easily participate in proper battery EOL
management, reducing the frequency of safety incidents from improper battery disposal (e.g., fires at waste
management facilities).
By developing new voluntary battery labeling guidelines, EPA seeks to increase consumer awareness of the
presence of batteries in products and to empower consumers to properly dispose of them, depending on their
local collection programs. Additionally, EPA aims to increase the proper identification and handling of batteries
in battery collection, sorting, and processing facilities, which should improve the safety of facility staff and also
increase the recovery of critical materials within the developing U.S. battery recycling infrastructure. These
activities are essential to advancing the circular economy for batteries and strengthening the U.S. supply chain
for critical materials.
The information in this white paper serves as foundational research to inform the development of the
forthcoming voluntary battery labeling guidelines as mandated by the BIL. This white paper synthesizes the key
findings from existing battery labeling guidelines to identify key information needs for EPA's voluntary battery
labeling guidelines and ensure alignment with U.S. and international battery-related mandates, including:
• U.S. federal battery labeling requirements, including those in the 1996 Mercury-Containing and
Rechargeable Battery Management Act (Battery Act).
• U.S. state EPR laws that include battery marking or labeling requirements.
• International battery labeling laws from the European Union (EU) and Japan.
• Voluntary battery labeling recommendations and guidelines.
This white paper is not a policy declaration by EPA, nor does it set forth any voluntary or required labeling
standards, recommendations, or guidelines. This white paper is intended as a reference material only. Inclusion
of any standard in this paper does not constitute an endorsement from EPA. The findings from EPA's research
activities are not intended as a comprehensive overview of all existing battery labeling standards and mandates;
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rather, they are meant to provide the necessary context to develop consistent voluntary battery labeling
guidelines and education on safe use, handling, storage, disposal, and EOL management for all battery types.
2 Considerations for Battery Labeling
BIL Section 70401 requires EPA to develop voluntary battery labeling guidelines consistent with existing U.S.
federal battery labeling requirements in the 1996 Battery Act and with international battery labeling standards.
Because the BIL does not specify the types of information that should be included in the forthcoming voluntary
battery labeling guidelines, EPA first compiled a breakdown of the types of information that are often included
in existing labeling guidelines, as shown in Table 1.
Table 1: Information in Existing Battery Labeling Requirements and Labeling Guidelines
Type of Information Description
Applicability
Battery types, uses, or chemistries covered by the existing labeling requirement or
voluntary standard.
Production
General product information such as the product name; manufacturer name and
contact information; packer, distributor, importer, or seller; country of origin; and
production date.
Battery-specific
Details about the battery, including the battery chemistry (e.g., color coding,
chemical symbols); cathode and anode identifiers (for lithium-ion batteries [LIBs]
only); voltage; capacity; model number; polarity; and non-spillable markings.
EOL management
Information or instructions on how to properly dispose of the battery. This may
include recycling symbols (e.g., the "chasing arrows" symbol, the crossed-out
wheeled bin) and/or disposal and recycling instructions for consumers.
Safety
Information aimed at reducing safety risks during use, storage, and/or disposal of
batteries or battery-containing products. This may include general warnings,
handling recommendations, and cautionary statements, as well as symbols,
markings, or warnings for dangerous goods and hazardous materials.
Transportation
Information about the safe transport of batteries and battery-containing products.
This may include references to U.S. Department of Transportation (DOT)
requirements for shipments of new, used, and EOL batteries.
Refurbishment and
recycled content
Information used to signal that a battery may contain a certain percentage of
recycled material or that a product may contain a refurbished battery.
Physical placement
and size of the label
Instructions on the placement and size of a physical label and on the use of virtual
information collection. Label placement depends on the battery's size; where it is
located within the product, vehicle, or equipment; and whether it is embedded (i.e.,
one that has been placed permanently into a product and is not intended to be
removed by the consumer).
Label design
Design elements including the color of the label font and/or background, as well as
the font type and size. Design elements are often tied to specific label content,
including safety warnings, battery chemistry, and EOL management.
Label durability
Specifications about the durability of the label, which may include a specification
that the label should last the entire life cycle of a battery or product.
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Based on feedback from EPA's virtual working sessions and responses to the request for information (RFI) that
EPA issued in 2022, EPA focused its labeling research on battery-specific information, safety, and EOL
management, as well as label design and durability. These pieces of information are needed to meet the stated
purpose of the guidelines, which is to increase battery recycling and reduce safety incidents. EPA reviewed U.S.
federal and state labeling requirements, international requirements, voluntary labeling standards, and other
relevant standards with this key information in mind. The next several sections summarize EPA's findings on how
existing requirements and standards address the need for communicating battery-specific information and
information on safety and EOL management via battery labeling. These findings also provide insights into how
current standards may align or conflict.
3 U.S. Federal Battery Labeling Requirements
This section reviews U.S. federal requirements for battery labeling. EPA did not attempt to cover all labeling
requirements for batteries and battery-containing products but focused its research on reviewing labels that
might be relevant for alignment with the BIL mandates. In the United States, lead-acid, nickel-cadmium (Ni-Cd),
and LIB chemistries are currently subject to national labeling requirements. Additionally, button cell and coin
batteries and products that contain these batteries are subject to warning labels for child safety.
3.1 The Mercury-Containing and Rechargeable Battery Management
Act (1996)
The 1996 Battery Act phased out the use of mercury-containing batteries and aimed to improve the collection,
recycling, and labeling of Ni-Cd and lead-acid batteries. Under the Act, manufacturers are required to include a
label on removeable batteries and on battery-containing products with non-removeable batteries if they are
regulated by the Act. Specifically, the Battery Act requires that labels for Ni-Cd and small sealed lead-acid (SSLA)
batteries display the following: the chasing arrows, the chemical name (for regulated batteries), and certain
phrases for proper disposal such as "BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY." For mercuric-
oxide batteries, the label must direct consumers to a collection site and provide a phone number for consumers
to call for information about proper disposal. The Battery Act has a provision that gives EPA the authority to
determine through rulemaking if additional battery chemistries are covered by the Act. The requirements in the
Battery Act specifically target retailers, manufacturers, and battery handlers, and are further summarized in
Table 3 in Section 8.2
3.2 Call2Recycle Recycling Labels (1998)
Although the 1996 Battery Act was a major milestone in battery recycling, it did not include key labeling
information for consumers and battery consolidators that would help facilitate recovery (e.g., information on
the cathode, anode, and electrolyte, and EOL management information). To address this concern, in 1998 EPA
partnered with the Rechargeable Battery Recycling Corporation (now Call2Recycle) and announced the
certification of a new label for rechargeable batteries and their packaging to reduce consumer confusion around
proper disposal of EOL rechargeable batteries. As presented in Figure 1, the labels provided a toll-free number
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that consumers could call for more information on how to dispose of the battery properly.3
3.3 Reese's Law (2022)
Passed in 2022, Reese's Law provides standards related to human safety. Specifically, Reese's Law aims to
prevent the ingestion of button cell or coin batteries and products containing these batteries.6 Reese's Law
required the U.S. Consumer Product Safety Commission (CPSC) to promulgate a rule for safety performance and
labeling of products and packaging.6 In the final rule, 88 FR 65296, effective September 21, 2024, CPSC required
warning labels on the packaging of all button cell and coin batteries; on the packaging of all products containing
button cell or coin batteries; in accompanying literature (including user manuals) with relevant batteries and
products; and directly on products containing button cell or coin batteries where practical (see Figure 2). Reese's
Law and the final rule promulgated by CPSC do not require the label to include battery-specific information or
information on production, EOL
management, or transportation.
However, the warning symbol is
intended to help alert consumers
to the presence of a battery,
which could assist with recycling
or EOL management options
once consumers identify the
battery that needs to be
managed.
INGESTION HAZARD: DEATH or serious injury can occur if ingested.
A swallowed button cell or coin battery can cause Internal Chemical Burns in
as little as 2 hours.
KEEP new and used batteries OUT OF REACH OF CHILDREN
Seek immediate medical attention if a battery is suspected to be swallowed
or inserted inside any part of the body.
Figure 2: Label for button cell and coin batteries, warning of ingestion
hazards. Source: CPSC. 2023?
3.4 Transportation Labeling for Lithium-ion Batteries
Transportation labeling is not a key focus of this white paper because labeling requirements for international
transportation of batteries are established by the International Civil Aviation Organization's Technical
Instructions, by the International Air Transport Association's Dangerous Goods Regulations, and by the
International Maritime Dangerous Goods Code. Additionally, country-specific regulations are enforced by the
country that enacted them. The U.S. DOT regulates domestic shipments of lithium-ion cells and batteries and
enforces international shipping requirements and U.S. laws on movements of hazardous materials, including
LIBs and lead-acid batteries.7,8 DOT developed a -uide for shippers of LIBs. which provides instructions and
examples of labels needed for shipping LIBs and products packed with or containing batteries. The DOT guide
includes information on exceptions for batteries being shipped for disposal or recycling. It also helps shippers
identify correct packaging for LIBs.
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Some battery collectors like Call2Recycle have worked with DOT to ensure that LIBs shipped for recycling are
properly labeled. Call2Recycle was issued a DOT special permit that allows the organization and its partners to
ship batteries via a specialized collection box.9 The Call2Recycle battery collection partnership programs ensure
proper handling and recycling of batteries by equipping partner locations with materials for collection and
shipping, including the label seen in Figure 3.9 Call2Recycle's shipping label focuses on safety by identifying that
a battery is present and should be handled properly.
A CAUTION
T
A
IF DAMAGED
LITHIUM ION BATTERIES INSIDE
Do not damage or mishandle this
package. If package is damaged,
batteries must be quarantined,
inspected and repacked.
Figure 3: Call2Recycle shipping label.
Source: Call2Recycle, n.d.9
4 State-Level Battery Labeling Requirements
In the United States, state-level battery labeling requirements are emerging. The EPR laws and accompanying
rulemakings that create labeling requirements differ across states, producing variations in state requirements.
For example, states may include different information on the label or use various means to communicate the
required information (e.g., use of different symbols for management). Adopted in 2022, California's Advanced
Clean Cars II New Vehicle Battery Labeling Requirements are the most comprehensive labeling mandates in
terms of the information required, but they only apply to large format vehicle batteries.10 Other California
battery-related laws—the California Responsible Battery Recycling Act of 2022 and the California Electronic
Waste Recycling Act of 2003—apply to small format batteries and battery-containing products.1112 Recent
legislation from Washington and Illinois extends labeling requirements to a combination of small, mid-, and large
format batteries and embedded batteries as described in Table 2.13 Many other states have passed laws related
to retail collection of used batteries and required signage to educate consumers about EOL battery
management, but these laws do not address labeling.
The Advanced Clean Cars II, Title 13, Section 1962.6 outlines battery label requirements for zero-emission
vehicles (ZEVs), plug-in hybrid electric vehicles (PHEVs), and hybrid electric vehicles (HEVs) for sale in California.10
The regulation requires battery labels to contain the following: a chemistry identifier, the minimum voltage of
the battery pack, the battery capacity, and a digital identifier. Additionally, the regulation requires labels in the
following locations: (1) the exterior of the battery or each portion of the battery pack, and (2) a visible location
in the engine compartment, powertrain, or cargo compartment, or on the driver's side doorjamb.
As of November 2024, 11 states and the District of Columbia have battery EPR laws applicable to primary and/or
rechargeable batteries.14 These EPR laws focus on establishing stewardship programs to increase the recycling
and collection of batteries. Three state-level battery EPR laws—those in California (2022), Washington (2023),
and Illinois (2024)—include labeling or marking requirements. Consistent across all three EPR laws is the
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requirement that batteries sold within the state include the battery chemistry on the label, as well as symbols or
indicators signaling that consumers should not dispose of the batteries as household waste. However, labels are
not required to provide information for consumers on where to recycle their batteries. The Washington and
Illinois laws note that the state rulemaking agencies may amend the labeling requirements to remain consistent
with any labeling requirements or voluntary standards established by federal law.11,13,15
Table 2 presents select examples of state laws that require battery labeling.
Table 2: Examples of U.S. State Laws Requiring Battery Labeling
State Law
Applicability
Label Content and Placement Requirements
California Advanced
Clean Cars II New
Vehicle Battery
Labeling
Requirements10
Applies to large format
vehicle batteries for electric
vehicles (EVs), ZEVs, HEVs,
and PHEVs.
Battery chemistry; cathode and anode; and
manufacturer and date of manufacture, as stated in
the Society of Automotive Engineers (SAE) standard
J2984. The label must be on the exterior of the
battery to be clearly visible and accessible when the
battery is removed from the vehicle.
California
Responsible Battery
Recycling Act of
202211 (EPR)
Applies to small format
primary batteries only.
Battery chemistry; language indicating that the
battery should not be placed in household waste. The
law does not specify where to place the label.
California Electronic
Waste Recycling Act
of 2003,12 amended
by Senate Bill 1215
Applies to all battery-
containing products.
Battery chemistry (information can be presented
either on the product label or on the manufacturer's
website). The law states that the label must be clearly
visible.
Washington Battery
Stewardship Law13
(EPR)
Applies to primary and
rechargeable small, medium-,
and large format batteries
and battery-containing
products.
Producer information, as size allows. Starting in 2030,
all new applicable batteries must be labeled to
ensure collection and recycling. Labels must identify
the chemistry of the battery and an indication that
the battery should not be disposed of as household
waste. The law does not specify where to place the
label.
Illinois Portable and
Medium-Format
Battery Stewardship
Act15 (EPR)
Applies to primary and
rechargeable small and
medium-format batteries and
battery-containing products.
Starting in January 2029, producers and retailers may
only sell small and medium-format batteries and
battery-containing products if the battery is marked
with a label that identifies battery chemistry and
indicates that the battery should not be placed in
household trash or recycling.
New York's Rechargeable Battery Recycling Law, passed in 2010, requires manufacturers to provide retailers
with information on how to safely handle and store rechargeable batteries, but it does not include specific
battery labeling requirements.16 Retailers are required to post point-of-sale signs in their stores notifying
consumers about the state's disposal ban and advising consumers to recycle batteries at the retailer's location.17
Forty-five states have implemented similar laws requiring lead-acid battery retailers to accept lead-acid batteries
from consumers and deliver them to recycling facilities. Of these states, 30 require retailers to post an
educational sign at the point-of-sale location, informing consumers about the proper disposal method for lead-
acid batteries. In some states, the chasing arrows symbol is required. The required language for this educational
sign varies among states, but the message that producers and retailers are responsible for lead-acid battery
recycling remains consistent.18
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5 International Battery Labeling Requirements
This section reviews battery labeling requirements from the EU and Japan, in consideration of the BIL's mandate
to develop voluntary U.S. battery labeling guidelines that align with existing international standards. Several key
features of the labeling requirements from these countries could serve as examples for EPA's development of
voluntary guidelines for the United States.
5.1 European Union Batteries Regulation (2023)
In 2006, the EU adopted a Batteries Directive, applicable to all member states, that regulates battery production
and disposal and requires the use of a symbol for the separate collection of batteries (see Figure 4). The EU
enacted the 2023 Batteries Regulation that will repeal the 2006 Batteries Directive as of 2025. The 2023 EU
Batteries Regulation does the following:
• Provides additional requirements regarding sustainability, EPR, safety, markings, information, and
labeling.19-20
• Updates the 2006 labeling requirements to include additional details on capacity, battery chemical
composition, carbon footprint values, and handling instructions.19,20 These new labeling requirements,
outlined in Annex VI of the regulation and summarized in Table 3 at the end of this document, go into
effect between 2025 and 2026.20
• Requires that every EV battery and industrial battery with a capacity of over 2 kilowatt-hours should
have an EU "battery passport," an official document that will accompany the battery throughout its
entire life cycle, from production to disposal.21 The battery passport will contain vital information about
the battery, including its composition, capacity, voltage, and other specifications. The EU battery
passport is one example of how labels can be used to share information along a product's value chain.
5.2 Battery Association of Japan Labeling Requirements (2000)
Japan established the Law for the Promotion of the Effective Utilization of Resources in 2000. The law required
manufacturers to indicate on labels how to properly recycle applicable batteries.22 To meet the requirements of
the law, the Battery Association of Japan specified labeling requirements for batteries to improve recycling;
however, there are limited studies on the impact of the labeling requirements on recycling rate. Labels provide
information for EOL management, identify battery chemistry through color coding, and identify toxic or
hazardous substances. The color scheme for identifying chemistry aligns with the following voluntary standards,
which are discussed in Sections 6.1 and 7.
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6 Voluntary Battery Labeling Standards
This section provides an overview of voluntary battery labeling standards, including globally recognized industry
standards from organizations such as SAE International, Battery Council International (BCI), and the Automotive
Recyclers Association (ARA).
6.1 Society of Automotive Engineers International Standards
SAE International is a global association of engineers and technical experts that develops voluntary consensus
standards. For the automotive industry or ground vehicle category, SAE has developed over 8,000 standards
applicable to various components of cars, including batteries. EPA reviewed SAE standards J2936 and J2984
because these provide a consistent recommendation for identifying the battery chemistry and including color
coding, the chasing arrows, and safety information in alignment with U.S. and international requirements.
However, industry experts participating in EPA's battery collection and recycling working sessions noted that the
SAE recommendations have not yet been widely implemented. SAE J2936 and J2984 are summarized in Table 3
at the end of this document.
SAE J2936-201212 Electrical Energy Storage Device Labeling Recommended Practice23 is a comprehensive
reference guideline for labeling any device used for energy storage, including "cell, battery and pack level
products used in mobility, stationary and secondary use applications." The information in these labeling
recommendations is intended for the automotive sector but is written for "anyone working in the field of energy
storage devices." The guideline recommends including the chasing arrows symbol and a chemistry identifier on
the label, with the chemistry denoted using the practice described in J2984. The recommended practices also
note other labeling information required by country, as well as practices recommended by the industry.
SAE J2984-202109 Chemical Identification of Transportation Batteries for Recycling24 is referenced in the J2936
guideline and offers a standardized way for rechargeable transportation battery manufacturers to denote
chemical composition using the system chemistry, cathode material identifiers and sub identifiers, anode active
material identifier, and miscellaneous information (e.g., flammable liquid, rare earths). The standard includes:
(1) battery definitions citing SAE J1715/2 and other relevant SAE definitions; (2) identification codes for the
battery chemistry and production referencing International Electrotechnical Commission (IEC) 62902, which
identifies electrochemical storage technologies (batteries and others) according to their chemistry; and (3)
recommendations for the physical placement of the identifier. The standard also includes examples of battery
chemistry identification. This standard does not include specific information on the label design and label
durability or other battery information (e.g., voltage, recycling instructions, safety information, handling,
storage, or transportation).
6.2 Battery Council International Recommended Practices Battery
Labeling Manual
BCI promotes the responsible manufacture, use, and recycling of batteries for energy storage applications. BCI's
Recommended Practices Battery Labeling Manual, last revised in 2020, summarizes labeling requirements for
lead-acid batteries from the United States, Canada, the EU, China, and Japan, as well as BCI-recommended (but
not legally required) labeling practices that are based on industry standards.25 The manual includes definitions of
common label terms, a table of labeling requirements, explanations of typical battery labels (including sample
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labels), and an appendix of reference materials. The labeling recommendations reflect major nationally and
internationally adopted laws and standards governing health, safety, and the environment, as of January 2020.
In the manual, elements of label contents and design are displayed on sample labels, as shown in Figure 5 and
Figure 6. The sample labels in the manual include descriptions and references to applicable U.S. or foreign laws
and other applicable standards. Letters in the symbols are further explained in the manual.
0>
©
[qS •-Product
i ]%«
[Brand Name]
Lead Acid Battery -*•—
12V, 16.0Ah, 750CCA
I WARNING Canter and ReemJuctne Harm Wash hands alter handing - mm P66Wairmg9 cago*
WARNING Risk ol lire,«.
t inverted u» Fdlow product dargmg iraOuctnns
ct contains
[ ]%recydo
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addition to documents, ARA also developed two stickers to place on vehicles to improve worker safety during
the dismantling and recycling processes, as shown in Figure 7 and Figure 8.25
A DANGER PELIGRO A
A
High Voltage.
Alio Voltaje.
Vehicle contains a
HIGH VOLTAGE
BATTERY
The battery and all
system components
can be DEADLY
if not properly handled
| Follow ARA Electric & Hybrid Vehicle Training
Standards before working on this vehicle.
I EV SAFETY BY ARA CERTIFICATION PROGRAM
Q
ARACertification.com
^REMOVED lELIMINADOQ
Please Note:
This vehicle
contained a
HIGH VOLTAGE
BATTERY
which has
been removed.
This vehicle is
READY
for
dismantling and
processing.
a Follow ARA Electric & Hybrid Vehicle Training
Standards before working on this vehicle.
' EV SAFETY BY ARA CERTIFICATION PROGRAM
SISoCIAT&N-
ARACertiflcation.com
Figure 7: ARA high-voltage "battery intact" sticker. Figure 8: ARA high-voltage "battery removed"
Source: ARA, 2020.2& sticker. Source: ARA, 2020.2B
7 Other Battery Safety and Labeling Standards
This section lists additional international standards relevant for both battery safety and labeling for EPA to
consider when developing the labeling guidelines. The list is non-exhaustive but represents standards identified
during research and through discussions with interested parties engaged with EPA's ongoing battery collection
and labeling working sessions. Certain standards could be incorporated into labeling legislation or rulemakings—
for example, Reese's Law prompted CPSC to adopt UL 4200A: Battery Testing and Labeling Services as a
response to the law's rulemaking mandate for button cell and coin battery safety.6,29 The list below
demonstrates that batteries are subject to many standards and requirements, making labeling a challenge due
to limited space and the various standards that may apply.
• The IEC is a nonprofit organization that develops and publishes international standards for all electrical,
electronic, and related technologies.
o IEC 62902: Secondary Cells and Batteries—Marking Symbols for Identification of Their
Chemistry.
o IEC 61429: Marking of Secondary Cells and Batteries with the International Recycling Symbol ISO
7000-1135.
o I EC/ISO TR 24729: Information Technology—Radio Frequency Identification for Item
Management—Implementation Guidelines, Part 2: Recycling and RFID Tags.
• The International Code Council's 2024 International Fire Code includes "regulations to safeguard life and
property from fires and explosion hazards." The 2024 version includes tools to manage LIB collection, a
section on the hazards of powered micromobility devices, a section on lithium-ion and lithium metal
batteries, and guidance on battery markings for fire and explosion hazards.
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• The American National Standards Institute (ANSI) is a nonprofit organization that coordinates U.S.
voluntary standards, including testing and safety standards for various types of batteries. ANSI has
published standards for safety alerts (not battery-specific), as well as general and safety standards for
portable batteries.
o ANSI Z535: Safety Alerting Standards.
o ANSI C18.1 Part 1: American National Standard for Portable Primary Cells and Batteries with
Aqueous Electrolyte—General and Specifications,
o ANSI C18.1 Part 2: American National Standard for Portable Primary Cells and Batteries with
Aqueous Electrolyte—Safety Standard,
o ANSI C18.2 Part 1: American National Standard for Portable Rechargeable Cells and Batteries-
General and Specifications,
o ANSI C18.2 Part 2: American National Standard for Portable Rechargeable Cells and Batteries-
Safety Standard.
o ANSI C18.3 Part 1: American National Standard for Portable Lithium Primary Cells and
Batteries—General and Specifications,
o ANSI C18.3 Part 2: American National Standard for Portable Lithium Primary Cells and
Batteries—Safety Standard,
o ANSI C18.5M Part 1: Portable Lithium Rechargeable Cells and Batteries.
• UL Solutions offers globally recognized safety standards for batteries used for energy storage, EVs, and
micromobility.28
o UL 1642: Standard for Lithium Batteries.
o UL 1974: Creating a Safe Second Life for Electric Vehicle Batteries,
o UL 2054: Standard for Household and Commercial Batteries,
o UL 2271: Standard for Batteries for Use in Light Electric Vehicle Applications,
o UL 2272: Standard for Electrical Systems for Personal E-Mobility Devices,
o UL 2849: Standard for Electrical Systems for E-Bikes.
o UL 4200A: Battery Testing and Labeling Services for Reese's Law.
o UL 60086-4: Standard for Safety for Primary Batteries—Part 4: Safety of Lithium Batteries,
o UL 9540: Energy Storage System Requirements.
• The National Fire Protection Association (NFPA) is a nonprofit organization offering over 300 codes and
standards, as well as professional training, education, and advocacy. Relevant NFPA safety standards
apply primarily to large format stationary energy storage batteries. These standards help ensure the
safety of those installing and working with the batteries. The standards do not specifically address
labeling for recycling.
o NFPA 855: Standard for the Installation of Stationary Energy Storage Systems,
o NFPA 70: National Electrical Code.
14
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8 Summary of Select Battery Labeling Requirements and Guidelines
Table 3 summarizes select existing battery labeling requirements and voluntary standards from the United States, the EU, BCI, and SAE
International.
Table 3: Summary of Select Requirements and Voluntary Standards
U.S. Battery Act of 19962
EU Batteries Regulation20
BCI Battery Labeling Manual25
SAE J2936 and SAE J2984 (aligns
with IEC 62902)23'24
Applicability
The Act applies to Ni-Cd and lead-
acid batteries.
The 2023 Batteries Regulation updates
the definitions of covered batteries to
include the following categories:
portable, industrial, automotive, EV,
and light means of transport (LMT).
The recommended practices apply
to SSLA batteries; starting, lighting,
and ignition (SLI) lead-acid
batteries; and their packaging.
SAE J2936 could apply to any device
used for energy storage, including
"cell, battery and pack level
products used in mobility,
stationary and secondary use
applications."23
Chemical
Symbol or
Identification
The Act requires chemical
identification of regulated Ni-Cd
or lead (Pb) batteries.
All batteries must include general
information on their category,
chemistry, and whether they are
rechargeable.
All batteries containing more than
0.002% Cd or 0.004% Pb must be
marked with the chemical symbol for
the metal concerned.
The manual recommends
compliance with the U.S. Battery
Act of 1996 requirement to include
a Ni-Cd or Pb label.
The manual recommends having a
chemical symbol on the battery
label.
Color coding:
• Ni-Cd: Yellow green
• Nickel-metal hydride: Orange
• Lithium-ion: Cobalt blue
• Pb: Silver
• Nickel-zinc: Green
Placement and
Legibility of
Statements
Label must be on each individual
battery or battery-containing
product, in addition to the
product packaging unless the
label on the battery or battery-
containing product is visible
through the packaging.
A QR code must be in high contrast to
the background color and large
enough to be easily readable by a
common QR code reader.
Required label elements should be
"clear and conspicuous, separated
from other text and graphics, and
not placed on the bottom of the
product."
Information must be displayed on
the largest panel or side of the
product. The label copy should be
clean and free of any dirt or excess
print. It should have a lower gloss
reflection to ensure readability. The
label should be on a background of
sharp contrasting color to ensure it
stands out to the user. The label
should be durable and remain intact
for the entire life of the product.
Recycling
Symbol or
Label
The chasing arrows symbol (or a
comparable recycling symbol) is
required for all regulated
batteries.
Label for Ni-Cd batteries: "nickel-
cadmium" or "Ni-Cd," with the
Batteries must display the crossed-out
wheeled bin (see Figure 4), which is
the EU symbol for separate
collection.31
The manual recommends
compliance with the U.S. Battery
Act of 1996 and EU requirements.
Batteries should display the chasing
arrows symbol.
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U.S. Battery Act of 19962
EU Batteries Regulation20
phrase "Battery must be recycled
or disposed of properly."
Label for rechargeable consumer
products containing
nonremovable Ni-Cd batteries:
"Contains nickel-cadmium
battery. Battery must be recycled
or disposed of properly."
Label for regulated lead-acid
batteries: "Pb" or the words
"lead," "return," and "recycle."
Label for rechargeable consumer
products containing
nonremovable regulated lead-
acid batteries: "Contains sealed
lead battery. Battery must be
recycled."
Labels must be in all capital
letters.
16
BCI Battery Labeling Manual25 SAE J2936 and SAE J2984 (aligns
with I EC 62902)23'24
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9 Key Findings
This review of U.S. and international battery labeling requirements and voluntary standards focuses on three of
the key information needs identified by EPA for the development of voluntary battery labeling guidelines: EOL
management information, battery specifications (including chemistry), and safety information. At present, a
single comprehensive standard requiring battery producers and manufacturers to label batteries and battery-
containing products for improved collection and safe recycling does not exist. Box 1 summarizes key findings
from the review of existing labeling requirements and voluntary standards that will help EPA focus on the types
of information needed to achieve the purpose of the voluntary battery labeling guidelines and align them with
existing requirements and standards.
Box 1: Key Findings from EPA's Review of Existing Labeling Requirements and Voluntary Guidelines
EOL management information labels are a work in progress, and there is limited evidence of their impact on
recycling.
• Existing labeling requirements in the United States, the EU, and Japan include messaging and/or
symbols indicating that batteries and battery-containing products should be recycled, but battery labels
do not provide clear instructions for users to determine where or how batteries should be collected.
• New labeling requirements that aim to improve information on EOL management have been adopted
in the EU, Washington State, and California in recent years, but not all are fully in effect as of November
2024. As such, governing bodies cannot evaluate the efficacy of these new labeling requirements in
improving recycling.
• Recycling symbols vary by region. The EU uses a crossed-out wheeled bin, whereas standards and
regulations in the United States and other regions reference the Mobius loop (i.e., chasing arrows
symbol).
Battery chemistry identification and rated capacity can help aid safe recycling, but these label elements are
not internationally standardized.
• SAE International provides a recommended chemistry identifier with anode and cathode information
for LIBs.
• Standardized color coding by chemistry is referenced in some regulatory requirements and voluntary
standards but is not widely adopted.
• Labeling guidelines for chemistry should be adaptable to new battery chemistries and new sorting
technologies.
Safety labeling or markings included in existing safety standards could be incorporated into law.
• Standards organizations have developed several safety standards applicable to specific battery formats,
including standards for safe use, storage, repair, reuse, and recycling. These safety standards could be
incorporated into federal or state law by reference.
• For small format consumer electric and portable batteries, U.S. federal law requires safety information
on the battery packaging to reduce the risk of ingestion (Reese's Law). Washington and California state
laws will require labeling to ensure proper EOL management; these labeling requirements are under
development as of January 2025.
• For micromobility or mid-format batteries, safety standards aim to tackle emerging safety issues and
reduce fire risks. For example, New York State incorporated safety standards into new laws on e-
mobility. Washington State will require labeling for EOL management; these labeling requirements are
under development as of January 2025.
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Box 1: Key Findings from EPA's Review of Existing Labeling Requirements and Voluntary Guidelines
• For large format vehicle batteries, motive equipment batteries, and stationary storage batteries,
voluntary standards and example labels aim to improve safety for recyclers and for reuse.
Existing industry guidelines can serve as a model for labeling recommendations and content considerations.
• International standards organizations compile requirements and recommendations for label
components—including content, design, placement, and durability—which can be used as a model for
EPA's voluntary labeling guidelines.
10 Next Steps
Moving forward, EPA will continue engaging with parties across the battery life cycle to develop the voluntary
battery labeling guidelines as required by the BIL. Specifically, in 2025, EPA will host working sessions on mid-
format and large format batteries in partnership with other federal agencies, battery manufacturers, retailers,
industry leaders, and state, local, and Tribal governments. The goal of these sessions is to build on feedback
received on effective label content and design considerations from the small format battery engagement
sessions. EPA will assess this feedback to inform the development and implementation of the guidelines. The
guidelines will focus on standardizing necessary information for different audiences to identify batteries and
battery-containing products and increase proper EOL management.
To bolster adoption of the voluntary battery labeling guidelines and increase their effectiveness, EPA will
conduct additional research on consumer education and messaging based on feedback gathered from working
session participants. EPA will develop and test messaging to ensure that the labeling guidelines resonate and
meet the needs of priority audiences, including municipalities, consumers, and recyclers. Additionally, EPA will
create a collection best practices toolkit to accompany the voluntary guidelines, which will help to improve EOL
battery management by increasing access to collection sites. EPA will also, in coordination with DOE, develop a
battery EPR framework that addresses battery recycling goals, cost structures for mandatory recycling, reporting
requirements, product design, collection models, and transportation of collected materials.
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References
1. Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429 (2021).
https://www.govinfo.gov/content/pkg/PLAW-117publ58/pdf/PLAW-117publ58.pdf
2. U.S. Environmental Protection Agency. (1997). Implementation of the Mercury-Containing and Rechargeable
Battery Management Act [EPA530-K-97-009], https://www.call2recycle.org/wp-
content/uploads/lmplementationoftheMercury-ContainingandRechargeableBatteryManagementAct.pdf
3. Call2Recycle. (2014, July 22). The Call2Recycle battery seal celebrates its 20th birthday!
https://www.call2recycle.org/the-call2recycle-battery-seal-celebrates-its-20th-birthday/
4. Call2Recycle. (2023, August 8). Steward relations information. Call2Recycle.
https://www.call2recycle.org/steward-relations-information/
5. U.S. Consumer Product Safety Commission. (2023, September 21). Safety standard for button cell or coin
batteries and consumer products containing such batteries. Federal Register.
https://www.federalregister.gov/documents/2023/09/21/2023-20334/safety-standard-for-button-cell-
or-coin-batteries-and-consumer-products-containing-such-batteries
6. Reese's Law, Pub. L. No. 117-171, 136 Stat. 2094 (2022). https://www.congress.gov/bill/117th-
congress/house-bill/5313
7. U.S. Department of Transportation. (2023). Lithium battery guide for shippers. Pipeline and Hazardous
Materials Safety Administration, https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2023-
07/Lithium%20Battery%20Guide.pdf
8. U.S. Department of Transportation, (n.d.). Shipping batteries safely by air: What you need to know. Pipeline
and Hazardous Materials Safety Administration.
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/PHMSA_battery_guide.pdf
9. Call2Recycle. (n.d.). Lithium ion labeling instructions, https://www.call2recycle.org/wp-
content/uploads/Lithium%20lon%20Labeling%20lnstructions.pdf
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10. Battery Labeling Requirements, Title 13 Section 1962.6 California Code of Regulations (2022).
https://ww2.arb.ca.gOv/sites/default/files/barcu/regact/2022/accii/2acciifrol962.6.pdf
11. Responsible Battery Recycling Act of 2022, Assembly Bill 2440, Chapter 351, California State Legislature
(2022). https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB2440
12. Electronic Waste Recycling Act of 2003: Covered Battery-Embedded Products, Senate Bill 1215, Chapter 370,
California State Senate 2021-2022.
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB1215
13. Marking Requirements for Batteries, Revised Code of Washington (RCW) 70A.555.130 (2023).
14. Product Stewardship Institute, (n.d.). EPR by product: Batteries. Retrieved March 5, 2024, from
https://productstewardship.us/products/batteries/
15. Portable and Medium-Format Battery Stewardship Act, Illinois Public Act 1033 (2024).
https://www.ilga.gov/legislation/publicacts/103/103-1033.htm
16. New York State Department of Environmental Conservation, (n.d.). Rechargeable battery recycling. Retrieved
February 19, 2024, from https://dec.ny.gov/environmental-protection/recycling-
composting/rechargeable-battery-recycling
17. New York Product Stewardship Council, (n.d.). Batteries. Retrieved March 20, 2024, from
https://nypsc.org/new-york-battery-legislation/
18. Battery Council International, (n.d.). State point-of-sale notice language. Retrieved March 5, 2024, from
https://batterycouncil.org/recycling-sustainability/state-point-of-sale-notice-language/
19. Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on Batteries and
Accumulators and Waste Batteries and Accumulators and Repealing Directive 91/157/EEC. Retrieved
February 27, 2024, from http://data.europa.eu/eli/dir/2006/66/2018-07-04/eng
20. Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 Concerning
Batteries and Waste Batteries, Amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and
20
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Repealing Directive 2006/66/EC. Retrieved February 27, 2024, from https://eur-
lex.europa.eu/eli/reg/2023/1542/oj
21. Rizos, V., & Urban, P. (2024). Implementing the EU digital battery passport. CEPS.
https://circulareconomy.europa.eu/platform/sites/default/files/2024-03/lqp5rxiZ-CEPS-
lnDepthAnalysis-2024-05_lmplementing-the-EU-digital-battery-passport.pdf
22. Act on the Promotion of Effective Utilization of Resources (Japan), Act No. 48 (1991).
https://www.japaneselawtranslation.go.jp/en/laws/view/3819/en
23. SAE International. (2012, December). SAE electrical energy storage device labeling recommended practice
(J2936). https://www.sae.org/standards/content/j2936_201212/
24. SAE International. (2021, September). Chemical identification of transportation batteries for recycling
(J2984). https://www.sae.org/standards/content/j2984_202109/
25. Battery Council International. (2020). Recommended practices: Battery labeling manual.
https://batterycouncil.org/resource/battery-labeling-manual-january-2020-revision-download/
26. National Salvage Vehicle Reporting Program, (n.d.). National Salvage Vehicle Reporting Program. National
Salvage Vehicle Reporting Program. Retrieved January 8, 2025, from https://nsvrp.org/
27. Automotive Recyclers Association. (2020). ARA benefits the industry, https://www.a-r-
a.org/uploads/l/2/0/8/120899140/ara_general_flyer_2020.pdf
28. Automotive Recyclers Association, (n.d.). Safely manage high voltage vehicles. Retrieved April 2, 2024, from
https://aracertification.com/electric-vehicles
29. U.S. Consumer Product Safety Commission, (n.d.). Button cell and coin battery business guidance. Retrieved
November 1, 2024, from https://www.cpsc.gov/Business-Manufacturing/Business-Education/Business-
Guidance/Button-Cell-and-Coin-Battery
30. Flux Power. (2019, October 23). Why UL certification is important for a lithium ion battery pack.
https://www.fluxpower.com/blog/why-ul-marks-are-important-for-a-lithium-ion-battery-pack
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31. Your Europe. (2024, August 19). WEEE label, https://europa.eu/youreurope/business/product-
requirements/labels-markings/weee-label/index_en.htm
Appendix: Relevant Legislation
The following sections include excerpts from relevant state, federal, and international legislation that state
requirements for battery labels.
Relevant Text from the Mercury-Containing and Rechargeable Battery
Management Act (1996)
SEC. 102. PURPOSE.
The purpose of this title is to facilitate the efficient recycling or proper disposal of used nickel-cadmium
rechargeable batteries, used small sealed lead-acid rechargeable batteries, other regulated batteries, and such
rechargeable batteries in used consumer products, by—
(1) providing for uniform labeling requirements and streamlined regulatory requirements for regulated
battery collection programs; and
(2) encouraging voluntary industry programs by eliminating barriers to funding the collection and recycling
or proper disposal of used rechargeable batteries.
SEC. 103. RECHARGEABLE CONSUMER PRODUCTS AND LABELING.
b) LABELING. —Each regulated battery or rechargeable
consumer product without an easily removable battery manufactured on or after the date that is 1 year after the
date of enactment of this Act, whether produced domestically or imported shall bear the following labels:
(1) 3 chasing arrows or a comparable recycling symbol.
(2)(A) On each regulated battery which is a nickel-cadmium battery, the chemical name or the abbreviation
"Ni-Cd" and the phrase "BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY."
(B) On each regulated battery which is a lead-acid battery, "Pb" or the words "LEAD," "RETURN," and
"RECYCLE" and if the regulated battery is sealed, the phrase "BATTERY MUST BE RECYCLED."
(3) On each rechargeable consumer product containing a regulated battery that is not easily removable, the
phrase "CONTAINS NICKEL-CADMIUM BATTERY. BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY."
Or "CONTAINS SEALED LEAD BATTERY. BATTERY MUST BE RECYCLED," as applicable.
(4) On the packaging of each rechargeable consumer product, and the packaging of each regulated battery
sold separately from such a product, unless the required label is clearly visible through the packaging, the
phrase "CONTAINS NICKEL-CADMIUM BATTERY. BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY."
or "CONTAINS SEALED LEAD BATTERY. BATTERY MUST BE RECYCLED," as applicable
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Relevant Text from California AB-2440 Responsible Battery Recycling Act
(2022)
Article 3. Stewardship Plans for Covered Batteries
42422.1. A stewardship plan for covered batteries shall include all of the following:
(p) Developing strategies in coordination with other program operators to develop and implement proper
labeling of covered batteries to ensure proper collection and recycling, by identifying the chemistry of the
covered battery and including an indication that the covered battery should not be disposed of as
household waste
42424.1. A program operator shall annually submit to the department, in the form and manner, and by the
date, determined by the department, an annual report, which the department shall make publicly
available that includes all of the following information for the preceding calendar year:
(1) (1) A report on coordination activities with other program operators, including covered battery collection
and recycling programs and electronic waste recyclers, with regard to the proper management or
recycling of collected covered batteries, for purposes of providing the efficient delivery of services and
avoiding unnecessary duplication of effort and expense.
(2) A description of efforts undertaken by a program operator to implement the required labeling of covered
batteries pursuant to Section 42422.1.
Relevant Text from California SB-1215 Electronic Waste Recycling Act (2003)
42466. l.(a) On and after January 1, 2026, a person shall not sell or offer for sale in this state a new or
refurbished covered electronic device, as defined in subparagraph (B) of paragraph (1) of subdivision (g)
of Section 42463, unless the item is labeled with the name of the manufacturer or the manufacturer's
brand label so that it is readily visible.
(b) A new or refurbished covered electronic device, as defined in subparagraph (B) of paragraph (1) of
subdivision (g) of Section 42463, battery-embedded product shall either be labeled with information
identifying the chemistry of the battery contained within the covered electronic devices sold by the
manufacturer or include that information on the manufacturer's internet website.
42467. On or before July 1, 2027, and at least once annually thereafter, each manufacturer of a covered
electronic device, as defined in subparagraph (B) of paragraph (1) of subdivision (g) of Section 42463,
sold in this state shall do both of the following:
(1) Submit to CalRecycle a report that includes all of the following information:
(A) An estimate of the number of covered electronic devices, as defined in subparagraph (B) of paragraph (1)
of subdivision (g) of Section 42463, sold by the manufacturer in the state during the previous year.
(B) The chemistry of the battery contained within the covered electronic devices, as defined in subparagraph
(B) of paragraph (1) of subdivision (g) of Section 42463, sold by the manufacturer.
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(C) A baseline or set of baselines that show the total estimated amount of recycled materials contained in
covered electronic devices, as defined in subparagraph (B) of paragraph (1) of subdivision (g) of Section
42463, sold by the manufacturer in that year and the increase in the use of those recycled materials from
the previous year.
(D) A list of those retailers, including, but not limited to, internet and catalog retailers, to which the
manufacturer provided a notice in the prior 12 months pursuant to Section 42466.2.
(2) Make information available to consumers that describes where and how to return, recycle, and dispose of
the covered electronic device, as defined in subparagraph (B) of paragraph (1) of subdivision (g) of
Section 42463, and opportunities and locations for the collection or return of the device, through the use
of a toll-free telephone number, internet website, information labeled on the device, information
included in the packaging, or information accompanying the sale of the covered electronic device, as
defined in subparagraph (B) of paragraph (1) of subdivision (g) of Section 42463.
Relevant Text from Washington State SB-5144—Providing for Responsible
Environmental Management of Batteries (2023)
Marking requirements for batteries.
(1) Beginning January 1, 2028, a producer or retailer may only sell, distribute, or offer for sale in or into
Washington a large format battery, covered battery, or battery-containing product that contains a
battery that is designed or intended to be easily removable from the product, if the battery is:
(a) Marked with an identification of the producer of the battery, unless the battery is less than one-half inch
in diameter or does not contain a surface whose length exceeds one-half inch; and
(b) Beginning January 1, 2030, marked with proper labeling to ensure proper collection and recycling, by
identifying the chemistry of the battery and including an indication that the battery should not be
disposed of as household waste.
(2) A producer shall certify to its customers, or to the retailer if the retailer is not the customer, that the
requirements of this section have been met, as provided in RCW 70A.555.030.
(3) The department may amend, by rule, the requirements of subsection (1) of this section to maintain
consistency with the labeling requirements or voluntary standards for batteries established in federal
law.
[ 2023 c 434 § 14.]
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Relevant Text from European Union (EU) Batteries Regulation {2023)(44) Batteries should be labelled in order to
provide end-users with transparent, reliable and clear information about batteries and waste batteries. That
information would enable end-users to make informed decisions when buying and discarding batteries and waste
operators to appropriately treat waste batteries.
Batteries should be labelled with all the necessary information concerning their main characteristics, including
their capacity and the amount of certain hazardous substances present. To ensure the availability of information
over time, that information should also be made available by means ofQR codes which are printed or engraved
on batteries or are affixed to the packaging and to the documents accompanying the battery and should respect
the guidelines of ISO/IEC Standard 18004:2015. The QR code should give access to a battery's product passport.
Labels and QR codes should be accessible to persons with disabilities, in accordance with Directive (EU) 2019/882
of the European Parliament and of the Council (17).
CHAPTER III
Labelling, marking and information requirements
Article 13
1. 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, batteries shall bear a label containing the general information
on batteries set out in Part A of Annex VI.
2. 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, LMT batteries and SLI batteries
shall bear a label containing information on their capacity.
3. 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, non-rechargeable portable batteries shall bear a label
containing information on their minimum average duration when used in specific applications and a
label indicating non-rechargeable'.
4. From 18 August 2025, all batteries shall be marked with the symbol for separate collection of batteries
('separate collection symbol') as shown in Part B of Annex VI.
a. The separate collection symbol shall cover at least 3% of the area of the largest side of the
battery up to a maximum size of 5 x 5 cm.
b. In the case of cylindrical battery cells, the separate collection symbol shall cover at least 1,5 % of
the surface area of the battery and shall have a maximum size of 5 x 5 cm.
c. Where the size of the battery is such that the separate collection symbol would be smaller than
0,47 x 0,47 cm, the battery does not need to be marked with that symbol. Instead, a separate
collection symbol measuring at least 1 x 1 cm shall be printed on the packaging.
5. All batteries containing more than 0,002 % cadmium or more than 0,004 % lead, shall be marked with
the chemical symbol for the metal concerned: Cd or Pb.
a. The relevant chemical symbol indicating the heavy metal content shall be printed beneath the
separate collection symbol and shall cover an area of at least one-quarter the size of that
symbol.
6. From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI.
The QR code shall provide access to the following:
a. (a) for LMT batteries, industrial batteries with a capacity greater than 2kWh and electric vehicles
batteries, the battery passport in accordance with Article 77;
b. (b) for other batteries, the applicable information referred to in paragraphs 1 to 5 of this Article,
the declaration of conformity referred to in Article 18, the report referred to in Article 52(3) and
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the information regarding the prevention and management of waste batteries laid down in
Article 74(1), points (a) to (f);
c. (c) for SLI batteries, the amount of cobalt, lead, lithium or nickel recovered from waste and
present in active materials in the battery, calculated in accordance with Article 8.
This information shall be complete, up-to-date and accurate.
7. The labels and the QR code referred to in paragraphs 1 to 6 shall 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, the labels and the QR code shall be affixed to the packaging and to the documents
accompanying the battery.
8. The Commission is empowered to adopt delegated acts in accordance with Article 89 to amend this
Regulation to provide for alternative types of smart labels for use instead of or in addition to the QR
code, in view of technical and scientific progress.
9. Batteries that have been subject to preparation for re-use, preparation for repurposing, repurposing or
remanufacturing shall bear new labels or shall be marked with markings in accordance with this Article
and containing information on their change of status in accordance with point 4 of Annex XIII, which
shall be accessible through the QR code.
10. The Commission shall, by 18 August 2025, adopt implementing acts to establish harmonised
specifications for the labelling requirements referred to in paragraphs 1, 2 and 3 of this Article. Those
implementing acts shall be adopted in accordance with the examination procedure referred to in Article
90(3).
Labelling and marking of batteries ANNEX VI LABELLING, MARKING AND INFORMATION REQUIREMENTS
Part A: General information on batteries
Information on the label of a battery shall comprise the following information regarding the battery:
1. information identifying the manufacturer in accordance with Article 38(7);
2. the battery category and information identifying the battery in accordance with Article 38(6);
3. the place of manufacture (geographical location of a battery manufacturing plant);
4. the date of manufacture (month and year);
5. the weight;
6. the capacity;
7. the chemistry;
8. the hazardous substances present in the battery, other than mercury, cadmium or lead;
9. usable extinguishing agent;
10. critical raw materials present in the battery in a concentration of more than 0,1% weight by weight.
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Part B: Symbol for separate collection of batteries
Part C: QR code
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.
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