Battery Passport: Unique Identifier, QR Code and Applicable Standards

The Batteries Regulation mandates no vendor technology, but it does mandate four precise things: a unique identifier compliant with the ISO/IEC 15459 series, a QR code compliant with Annex VI Part C, open standards with no vendor lock-in, and full interoperability with other European Digital Product Passports. That framing — Articles 77(3), 77(5) and 78(a) — leaves real technical choice, provided you understand its three layers.

What Article 77(3) requires of the identifier

The text is direct: "The battery passport shall be accessible through the QR code referred to in Article 13(6) which links to a unique identifier that the economic operator placing the battery on the market shall attribute to it."

Then: "The QR code and the unique identifier shall comply with the ISO/IEC standards 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014 and 15459-6:2014 or their equivalent."

Three words open everything: or their equivalent. The Regulation sets a level of requirement — global uniqueness, issuance under a registered authority — not an implementation. The Commission may also amend the list by delegated act in light of technical progress.

The QR code itself is described in Annex VI Part C; recital 44 points to ISO/IEC 18004:2015 and requires labels and QR codes to be accessible to persons with disabilities under Directive (EU) 2019/882. Article 13(7) adds that they must be printed or engraved visibly, legibly and indelibly — a real constraint for a battery exposed to vibration, heat and solvents for ten to fifteen years.

Three layers not to confuse

Confusing these layers produces the market's most common error: believing that "the DPP requires GS1 Digital Link". It does not — we detailed this in Do you have to use GS1 Digital Link for your DPP?. GS1 Digital Link is the dominant and recommended syntax, particularly for organisations already using GTINs; it is not a legal obligation.

The openness requirement of Article 77(5)

This is probably the Regulation's most demanding provision when choosing a solution: "All information included in the battery passport shall be based on open standards, be in an interoperable format, transferable through an open interoperable data exchange network without vendor lock-in, machine-readable, structured and searchable."

The phrase without vendor lock-in appears verbatim in the Regulation. It is not a best-practice recommendation: it is a legal requirement, reinforced by Article 78(e), which requires the passport to remain available after the responsible operator ceases its activity.

The six European DPP standards that apply by cross-reference

Article 78(a) requires the battery passport to be "fully interoperable with other digital product passports required by Union law concerning eco-design", across technical, semantic and organisational aspects.

Through that cross-reference, the standards from CEN-CENELEC JTC 24, developed for the ESPR, become structuring for batteries. Six of the eight are cited in the Official Journal of the European Union by Commission Implementing Decision (EU) 2026/1736, in July 2026:

Their citation in the Official Journal confers a presumption of conformity with the requirements of Articles 10 and 11 of the ESPR. For a battery these standards do not apply directly — the basis remains Article 78 of the Batteries Regulation — but they are the only common technical corpus capable of satisfying the interoperability requirement of Article 78(a).

Sector reference models: DIN DKE SPEC 99100 and Battery Pass

Alongside law and standards sits a third corpus: the work of the Battery Pass consortium, which publishes a Data Attribute Longlist v2.0 and a Data Model v2.0 built on the DIN DKE SPEC 99100 specification, plus a test environment for validating an implementation.

These documents carry no regulatory weight. Their value is to offer a reference model where the Commission guidance of 15 August 2026 stops at the list of 71 data points and their applicability, without defining units, formats or types.

The four technical decisions to make

1. 01.The identifier scheme: compliant with the ISO/IEC 15459 series or equivalent, aligned with your existing systems — GTIN if you are already in the GS1 ecosystem, another scheme otherwise.
2. 02.The URL syntax: GS1 Digital Link, EN IEC 61406-2 or ISO/IEC 18975 — three compliant options.
3. 03.The data carrier: QR code mandatory, with a marking method that survives the battery's service life. Nothing prevents adding a second carrier.
4. 04.The data model: the Commission's 71 points as scope, DIN DKE SPEC 99100 as the model, EN 18216 to 18223 as the exchange framework.

In short

The Batteries Regulation requires a unique identifier compliant with the ISO/IEC 15459 series or equivalent, a QR code compliant with Annex VI Part C, open standards with no vendor lock-in, and full interoperability with other European DPPs. It mandates no vendor technology, and specifically not GS1 Digital Link. The six EN standards cited in July 2026 provide the common technical framework; DIN DKE SPEC 99100 and the Battery Pass consortium provide the sector data model.

Arianee runs an open DPP infrastructure compatible with the identifier syntaxes and data carriers allowed by the standards, with no vendor lock-in. See our Battery Pass page, our article on GS1 Digital Link and the DPP, or request a demo.

Sources: Regulation (EU) 2023/1542, Articles 13, 77 and 78 and Annex VI — consolidated text of 31 July 2025 (EUR-Lex) · Commission Implementing Decision (EU) 2026/1736 citing the harmonised DPP standards (EUR-Lex) · Guidance Document: Digital Batteries Passport – data points by category, v2.0, 15 August 2026 (European Commission) · Battery Pass consortium — Data Attribute Longlist v2.0 and Data Model v2.0.