Introduction: DPP and the status-quo for batteries

Under current battery regulations in the EU, the Digital Product Passport (DPP) — used to capture lifecycle, origin, and regulatory data — relies on QR codes as the data carrier. QR codes are cheap, easy to print, and easy to read with any smartphone or scanner. However, in practice QR codes have shown limitations in industrial contexts — especially when applied to batteries or battery cells, where robustness, security, and traceability over the full product life cycle are essential.

This article explores why replacing or augmenting QR codes with RAIN RFID tags makes sense, particularly for battery packs, modules, and cells, and outlines the additional value RAIN RFID brings beyond DPP compliance.

Why QR codes for DPP on batteries are not always practical

Although QR codes are the mandated standard for DPP data carriers on many products, they have practical drawbacks when used on batteries:

  • Need for visibility and line-of-sight: QR codes, need light, must be visible, and unobstructed to be scanned. On battery packs and cells — often enclosed in modules, covered, or embedded in metal housings — access may require disassembly. This reduces the practicality of scanning, fast discovery of the DPP data carrier especially for field checks or maintenance.
  • Fragility / tampering / wear-out: Battery packs are subject to handling, mechanical stress, environmental exposure, and long service life. A QR code printed on a label can fade, be scratched off, or be covered by dirt or residue — hampering readability at critical times (e.g., during service, recycling, or resale).

Because of these limitations, QR codes, while acceptable for simple DPP needs, often prove impractical for the full lifecycle management of batteries, especially for safe, secure, and tamper-resistant tracking.

Why RAIN tags outperform QR codes for the DPP use case (and more)

RAIN RFID is a standards-based, wireless communication technology that utilizes the ISO/IEC 18000-63 air-interface protocol (also known as GS1 UHF Gen2).” For DPP (Digital Product Passport) on batteries RAIN technology offers multiple advantages over QR codes.

Key strengths of RAIN RFID vs QR codes (in DPP context)
  • No light and no line-of-sight required: RAIN RFID tags can be read even when embedded inside a product, under covers, or when stacked among other items. This allows data retrieval even when battery cells or modules are not directly visible. 
  • Bulk / high-speed reading: RAIN systems can read many tags in seconds — hundreds to thousands per second — enabling rapid inventory, quality control, or audit of many battery packs at once. 
  • Unique, secure identity and anti-counterfeit capability: Each RAIN RFID tag contains a unique chip-based ID (TID) plus user-writable memory (EPC or other data fields). This makes it much harder to copy or replicate tags than to visually duplicate QR labels.
  • Writable / updatable data: RAIN RFID tags’ user memory bank can be updated after initial deployment — for example, to record manufacturing data, repair history, batch number, or later events — without replacing the tag. 
  • Durability over lifecycle: Properly designed RAIN RFID tags (embedded or robust tags) can survive through harsh conditions over the lifetime of the product: mechanical stress, high/low temperature, moisture, wear, etc. 

Because of these benefits, RAIN RFID — either alone or combined with QR — is much better suited than QR-only for products like battery packs that require lifetime traceability, durability, and tamper resistance.

In fact, the industry increasingly uses hybrid labels: a visible QR code (for human-readable data or quick checks) plus an embedded or attached RAIN tag for robust digital tracking and traceability and with this sets a de-facto industry standard.

Additional value from RAIN tags on batteries or battery cells (beyond DPP)

Even when not mandated by regulation, integrating RAIN tags into battery packs or cells can deliver considerable operational, safety, and business benefits:

  • OEM identification: In complex battery packs, for example in electric vehicles or energy storage systems, RAIN tags can encode the identity of original equipment manufacturer (OEM), batch, manufacturing date, serial number, etc. This becomes invaluable during repairs or maintenance — e.g., when replacing cells or modules, one can verify that replacements are genuine OEM components. Embedding RAIN tags inside cells or modules (rather than as an external label) makes it much harder for malicious actors to substitute genuine cells with fake, lower-grade ones. Removing or tampering with an embedded RAIN tag is significantly more difficult, especially without detection, than peeling off an external QR label.
  • Improved safety monitoring — e.g., temperature tracking: Advances in RAIN technology now allow tags to include sensors and to harvest energy from RF readers, enabling passive, battery-free condition monitoring. For example, Powercast has demonstrated battery-free RAIN-based sensor tags that monitor temperature and humidity, without wires or maintenance.
  • Thermal-runaway detection / early warning: In battery packs — especially high-performance, high-energy ones (e.g., EVs) — temperature anomalies can prelude thermal runaway or other dangerous failures. Embedding a RAIN temperature-sensor tag can alert to abnormal increases — whether during operation (e.g., driving) or storage (e.g., in a warehouse).
  • Improved insurance and liability handling: Especially for high-value battery users (cars, energy storage systems, etc.), having a robust record of battery history, environmental exposure, and safety events (stored via RAIN / DPP) can facilitate insurance coverage for temperature-related risks and provide documented evidence in case of claims.
  • Lifecycle traceability and recycling / circular economy benefits: With RAIN tags that survive the full lifetime of a battery pack, recyclers or second-life processors can reliably identify cell origin, chemistry, history, and use — critical for safe recycling and remanufacturing, and for compliance with circular-economy or regulatory requirements.

Guidance: How to implement RAIN tag in batteries

To get the full benefit of RAIN tags in batteries or battery packs, consider the following guidance:

Performance and suitability of RAIN RFID on batteries
Where and how to place the RAIN tag
  • Embedded inside: For maximum protection against tampering or removal, embed the RAIN tag inside the battery cell housing or module casing (e.g., between layers, within a composite or polymer part). This ensures the tag stays with the cell/module throughout its entire life, and makes unauthorized substitution or removal significantly harder.
  • Surface on non-metal part: If embedding is not feasible, affix the RAIN tag on a non-metal surface of the battery pack — or use tags designed for on-metal adhesion if necessary. Automotive-grade RAIN tags exist that can cope with metal surfaces and harsh environments.
  • Tag material and durability: Use tags that are specified for industrial / automotive environments — resistant to vibration, temperature extremes, moisture, and chemical exposure — to ensure long-term reliability.
  • Integration with BMS or cloud DPP: For enhanced safety and traceability, connect RAIN tag data with the battery management system (BMS) and/or a cloud-based DPP backend. For example, temperature data from a RAIN sensor could be read by a fixed reader in a warehouse or workshop and automatically stored in the DPP record.

Why adding RAIN RFID to accepted list of data carriers makes sense: A call to action

The current regulatory reliance on QR codes for DPP data carriers misses a technical opportunity. Given the clear advantages of RAIN RFID — durability, security, write-ability, ability to embed inside the product, suitability for harsh environments, and support for advanced use cases (e.g., safety monitoring, aftermarket service, repair, circular economy) — it is justified to include RAIN tag (or RAIN + QR hybrid) among the accepted data carriers for batteries.

In particular, the regulatory framework (e.g., via the enabling clauses for delegated acts under the battery regulation) should be used to allow alternative or additional smart tags in recognition of technical and scientific progress. In practice, accepting RAIN RFID as an official data-carrier for battery DPP would:

  • Raise traceability standards and robustness in the battery value chain.
  • Improve safety and fraud prevention, especially when battery cells or modules are replaced, refurbished, or reused.
  • Enable data beyond static manufacturing info: repair history, temperature logs, cell provenance, and recycling metadata — supporting circular economy goals.
  • Provide a durable and tamper-resistant link between physical battery modules and their digital product passports for the product’s full lifetime.

Therefore, we urge regulators, standardization bodies, and industry stakeholders to revise the rules and include RAIN RFID among the allowed data carriers for battery DPP — either as a replacement for, or complement to, QR codes.

Conclusion

While QR codes have been useful and are currently the prevalent solution for DPP data carriers on batteries, they were never designed for the rigors and complexity of battery lifecycle management, safety monitoring, and long-term traceability. RAIN RFID offers a far more robust, flexible, and future-proof solution — with anti-counterfeit features, embedability, dynamic writeable memory, and potential for safety-related sensor data.

Given the technical maturity of RAIN RFID, and the rapid innovation in passive sensor-equipped RFID tags (e.g., temperature monitoring), there is a compelling case for regulators and industry to adopt RAIN as an acceptable (if not preferred) method for battery data carriers. Embracing RAIN RFID is not just about better traceability — it’s about building safer, more transparent, and more sustainable battery supply chains.