2026-04 · 7 min read · All articles

Small Batteries and the DPP: When the QR Code Can Go on the Packaging

For a 75 kWh EV battery pack there's no question — the QR code goes on the battery itself. But what about a CR2032 coin cell, an AAA, or a button battery inside a hearing aid? EU Battery Regulation 2023/1542 has an explicit fallback for small batteries. Here's how to apply it correctly.

The rule in one sentence

Article 13(6) of Regulation (EU) 2023/1542: the QR code pointing to the Digital Product Passport must be printed or engraved on the battery itself — unless the nature or size of the battery makes that impossible, in which case it goes on the packaging and the accompanying documents.

What the regulation actually says

The QR code 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, it shall be affixed to the packaging and the documents accompanying the battery.
— Regulation (EU) 2023/1542, Article 13(6)

The exception covers labeling AND the DPP

Battery Regulation treats both obligations the same way and applies the same fallback cascade:

• Physical labeling — Art. 13(1–5), Annex VI: manufacturer, capacity, chemistry, crossed-out wheelie bin, Cd/Pb symbols, CE marking
• DPP data carrier — Art. 13(6), Art. 77, Annex XIII: QR code or GS1 DataMatrix linking to the online passport

Both follow the same 3-step cascade:

1. Directly on the battery (default)
2. On the packaging (if size or shape makes direct marking impossible)
3. In the accompanying documents (if even the packaging is impractical)

When is the packaging option allowed?

How small can a QR code or DataMatrix physically be?

Regulation aside, printing has physical limits. At minimum you need:

• QR code — about 10 × 10 mm (version 1, 28 modules, low data density) to be reliably scanned by a commercial smartphone
• GS1 DataMatrix — about 6 × 6 mm, which is the practical reason the regulator prefers DataMatrix for tiny items

A typical AAA cell is ~10 mm in diameter and 44 mm long. A compliant QR simply does not fit on the curved cylindrical body. A 6 mm DataMatrix might — but printing with sufficient contrast on a metallic surface is another story. For most portable cells, packaging is the realistic answer.

What counts as "packaging"?

The regulation means retail packaging — the one that reaches the end consumer, not shipping or transport packaging.

• A blister pack of 4 × AA batteries → the blister is the packaging
• A tray of 20 button cells with sealed strips → the tray (or each individually sold strip) is the packaging
• A smartphone with embedded battery → the device box is the packaging

A large cardboard box containing 200 retail blister packs does not satisfy the obligation. The data carrier must remain with the product when it reaches the consumer.

Accompanying documents — the last resort

Only when neither the battery nor the packaging is practical. Typical cases:

• Batteries sold exclusively B2B with technical documentation
• Embedded batteries in certified medical devices with strict labeling constraints
• Safety-critical industrial batteries where the packaging is destroyed before the end user

Practical guidance for producers

1. Measure the printable area before choosing a carrier format — not after your artwork is finalised
2. Prefer GS1 DataMatrix when the product is under ~50 mm in any dimension — smaller footprint, same linking capability
3. Test the scan with at least three commercial smartphone scanners at the final print size and actual substrate
4. Use the same canonical URL on battery, blister, box and manual — a single GS1 Digital Link, one passport view
5. Document the decision in your technical file — authority inspectors will ask why you chose packaging over direct engraving

How DPP.GS handles this

The dashboard generates QR codes and GS1 DataMatrix symbols in any physical size, with vector SVG output ready for artwork. For button cells and AAA producers we recommend:

• format=datamatrix — 6 mm minimum, GS1-compliant with FNC1 separator
• A quiet zone of at least 1.5 mm around the symbol on blister artwork
• The same GS1 Digital Link URL on the accompanying paper manual as a regulatory fallback

Whatever carrier and location you choose, one URL works for both the EU DPP and US GS1 Sunrise 2027 — a single GS1 Digital Link resolves to the same passport viewer.

TL;DR

• A battery too small to carry a QR? The packaging is allowed, and the regulation explicitly permits it.
• Apply the same cascade for labeling and DPP: battery → packaging → accompanying documents
• "Packaging" means retail packaging that reaches the consumer, not shipping cardboard
• GS1 DataMatrix (6 mm) is usually the right call for sub-50 mm products