Duty overview - rechargeable batteries

Applies to loose rechargeable portable batteries such as NiMH AA/AAA cells and to rechargeable portable batteries built into products. Product design for user replacement remains on the separate replaceable-design page.

Requirement Cell Manual Packaging QR Article
Brandname / producer identification Art. 13(1)
battery category and model identifier Art. 13(1)
place and date of manufacture: YYYY-MM-XX Annex VI
weight, chemistry, relevant substances and critical raw materials Art. 13(1)
capacity in mAh; add Wh for Li-ion packs and products where energy content matters Art. 13(2)
CE, crossed-out wheeled bin, lot/serial code Art. 13(4)-(5)
safe charging, use and storage instructions Art. 12
heat, fire, short-circuit and child-safety warnings Art. 12
disposal and separate collection instructions Art. 12
replacement or service information where the battery is built in Art. 11
link to online battery information and QR target page Art. 13(6)
complete manufacturer and importer details Art. 38
model, lot, manufacturing place and manufacturing date Art. 38
capacity, voltage, Wh where relevant, chemistry and weight Annex VI
composition, hazardous substances and critical raw materials over 0.1% Annex VI
safety, charging, recycling and disposal warnings Art. 12
GTIN/SKU, model, producer, importer Art. 13(6)
capacity, voltage, Wh, chemistry and weight Annex VI
manufacturing place and manufacturing date Annex VI
safety, charging, replacement and recycling information Art. 13(6)
compliance links and document references Art. 13(6)
No requirements found.

Examples

Loose rechargeable AA/AAA cells

Example: rechargeable NiMH AA or AAA cells sold as loose batteries or in a blister pack.

Brandname
AA / HR6 NiMH
Rechargeable battery
1.2V 2000mAh
Energy: 2.4Wh
LOT: HR6260513A
MFG: YYYY-MM-XX
Weight: XX g
AA
CE mark Separate collection symbol
Shown on cell / jacket if space allows
Brandname
AA / HR6 NiMH
Rechargeable battery
1.2V 2000mAh
Energy: 2.4Wh
LOT: HR6260513A
MFG: YYYY-MM-XX
Weight: XX g
Imp: IMPORTER GmbH
CE
[crossed-out wheeled bin]
For rechargeable AA/AAA cells, capacity in mAh is the key practical marking. Wh can be added as calculated energy content: Wh = nominal voltage x Ah. If the full importer or manufacturer block does not fit, move full details to packaging or an accompanying document.

Built-in rechargeable batteries

Example: compact power bank, speaker, flashlight, shaver, toy, or small household device with a built-in rechargeable Li-ion battery.

Product / rating label example
Model: PB-LITE-01
Battery: Rechargeable Li-ion battery
Nominal voltage: 3.7V
Rated capacity: 2200mAh
Energy: 8.14Wh
Lot / Serial: PB260513A
MFG: YYYY-MM-XX
Weight: XX g
CE
[crossed-out wheeled bin]
Built-in rechargeable batteries need the normal battery label information plus product-level documentation. The battery, host product, packaging, manual, and digital QR information must be treated as one compliance package.

Capacity marking: mAh and Wh

What the EU rule says
  • From the label trigger date, rechargeable portable batteries must carry capacity information.
  • For AA/AAA rechargeable cells, mAh is the normal supplier-facing capacity value.
  • The Regulation does not state that every rechargeable portable battery must show both mAh and Wh as a fixed double unit.
Practical Mega Step artwork rule
  • For loose AA/AAA NiMH: show mAh; add Wh where space allows.
  • For Li-ion packs, power banks, and built-in battery products: show both mAh and Wh.
  • Formula: Wh = nominal voltage x Ah. Example: 3.7V x 2.2Ah = 8.14Wh.
This keeps the supplier artwork practical while avoiding a false statement that Wh is always explicitly required by Article 13(2) for every rechargeable portable battery.

What still belongs on packaging and documents

Packaging / manual / online information
Loose rechargeable AA/AAA
  • full manufacturer and importer details if they do not fit on the cell
  • model / IEC code, lot, chemistry, voltage, mAh, and optional Wh
  • charging, storage, short-circuit, child-safety, and disposal warnings
  • future QR target page and linked compliance information
Built-in rechargeable batteries
  • full manufacturer name, address, website, and email
  • full importer name, address, website, and email
  • product-specific battery service information where applicable
  • safety information for use, charging, storage, and disposal
  • future QR target page and linked digital product information
  • later battery label data under Annex VI Part A and capacity label logic
Do not mix the two cases: loose rechargeable AA/AAA cells are a battery artwork problem; built-in rechargeable batteries are a battery plus product documentation problem.

What the manual and online page must cover

Manual / insert
  • how to use and charge the product safely
  • where to find the separate replaceable-design and service information, where applicable
  • fire, heat, short-circuit, and child-safety warnings
  • disposal and separate collection instructions
Permanent online information
  • link to the replaceable-design guide, where applicable
  • battery safety and disposal information
  • future QR-linked product page structure
  • later DoC and compliance references

QR code and digital product information

Same requirements for all portable batteries. The QR code links to a target page with identification, label data, contacts, safety and recycling per Regulation (EU) 2023/1542.

  • suitable for later product database connection
  • language selection in the page header
  • safety, recycling and compliance information
  • for private-label products: show actual producer/factory in addition to brand and importer
  • for small cells: place QR on packaging or accompanying documents when the cell is too small
Important for suppliers: brand, actual producer/factory and EU importer must remain clearly separated and traceable on the QR target page.
Clickable example target page