In short: From 18 February 2027, LMT batteries for e-bikes and e-scooters that are newly placed on the EU market or put into service need a battery passport, regardless of capacity. The obligation lies with whoever places the battery on the market. That includes importers.
What Are LMT Batteries?
LMT stands for Light Means of Transport. The EU Battery Regulation (EU) 2023/1542 defines LMT batteries as batteries for wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power. In practice, this includes:
- E-bikes and pedelecs (pedal-assisted bicycles; up to 250 W and 25 km/h without EU type approval, more powerful pedal-designed drives with assistance up to 25 km/h and at most 1,000 W as category L1e-A, the powered cycle)
- E-scooters with a seat and S-pedelecs (category L1e-B, two-wheel mopeds up to 45 km/h and up to 4 kW)
- Electric kick scooters, which have no L-category type approval under Article 2(2) of Regulation (EU) No 168/2013 because they carry no seating position, but whose batteries are LMT batteries all the same
- E-motorcycles, as long as the battery is sealed and weighs no more than 25 kg; above that it counts as an electric vehicle battery
- Electric wheelchairs and mobility scooters
- Light electric utility vehicles (e.g., registered e-cargo bikes)
Crucially: classification as an LMT battery does not depend on capacity. Article 3(1)(11) requires a battery that is sealed, weighs 25 kg or less and is specifically designed to provide traction to wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, including type-approved vehicles of category L. It must also not be an electric vehicle battery. Only when all four conditions are met is it an LMT battery. Heavier traction batteries are electric vehicle batteries. Within that definition, intended use decides: a 500 Wh battery in an e-bike is an LMT battery; the same battery in a vacuum cleaner would be a portable battery. Our battery passport overview covers all battery categories.
Why LMT Manufacturers Must Act Now
The European market for e-bikes and e-scooters is large: according to the Bicycle Industry and Market Profile published by the industry association CONEBI, around 5.1 million e-bikes were sold in Europe in 2023, after 5.5 million in 2022. At the same time, the market is characterized by many small and medium-sized manufacturers who often have fewer regulatory resources than large EV manufacturers.
These are precisely the manufacturers affected by the battery passport mandate from February 2027, and many of them don't know it yet. The battery passport applies not only to Tesla and BMW, but also to the e-bike manufacturer with 50 employees.
Anyone who breaches the obligations risks penalties. Under Article 93 of the Regulation, the Member States lay them down, and they must be effective, proportionate and dissuasive. What this means in practice is explained in our article Battery Passport Penalties: What Non-Compliance Costs.
Timeline: What Deadlines Apply to LMT Batteries?
LMT batteries share some deadlines with EV and industrial batteries, while others are later:
- 18 February 2027: Digital battery passport becomes mandatory, including for LMT batteries
- 18 August 2027: Supply chain due diligence obligations
- 18 August 2031: Recycled content minimum quotas for EV and industrial batteries (not yet for LMT)
- 2033: Recycled content obligations also for LMT batteries
- 18 August 2036: Tightened recycled content quotas (Stage 2)
Important: although LMT batteries are only affected by recycled content quotas from 2033, they must declare recycled content in the battery passport from 2027. For details on quotas, see our article Recycled Content in the Battery Passport.
Batteries already placed on the EU market before 18 February 2027 do not need a passport retroactively. Under Article 77(1), the obligation applies to every battery placed on the EU market or put into service from that day. That includes a replacement battery that newly enters the market from then on.
What Data Must LMT Manufacturers Capture?
LMT batteries are subject to the same seven data categories of DIN SPEC 99100 as EV and industrial batteries:
- Identification: Manufacturer, GTIN/article number, serial number, battery model, manufacturing facility
- Materials: Battery chemistry (often LFP or NMC for e-bikes), hazardous substances, critical raw materials
- Carbon footprint: Total carbon footprint per kWh rated capacity
- Due diligence: Supply chain due diligence reports
- Circularity: Disassembly instructions, recyclability, spare parts availability
- Performance: Rated capacity, rated voltage, energy content, expected lifespan
- Labeling: EU declaration of conformity, CE marking, battery symbols
For a comprehensive overview of all data fields, read our article What is a Battery Passport?
Who sees which data on an e-bike battery
The passport is not a single document but a collection with different access rights. For an e-bike manufacturer the split matters in practice, because it decides what a customer sees at the counter and what a service workshop gets.
- Public, for every scan: the information under Annex XIII point 1. That covers composition, rated capacity, voltages, expected lifetime in cycles, round trip efficiency, the EU declaration of conformity and the waste management information. A customer in the shop sees the key figures, not the internals.
- Only with a legitimate interest: the information under Annex XIII points 2 and 4. Point 2 holds the detailed composition, part numbers, contact details of spare part suppliers, exploded diagrams, the sequence of disassembly steps and the safety measures. Point 4 holds the data on the individual battery, so state of health, status and usage data. Article 77(2) expressly names repair operators, remanufacturers, second-life users and recyclers as the purpose.
- Only for authorities and notified bodies: the results of the test reports under Annex XIII point 3.
Who counts as a person with a legitimate interest, which of this information they may access and to what extent they may download, share, publish and reuse it is to be laid down in an implementing act under Article 77(9). How far it has progressed is shown on our overview What the EU still has to deliver. For implementation that already means one thing: restricted fields must not appear in the source of the public passport page at all, not merely be hidden. Publishing your disassembly drawings by accident gives your knowledge away to anyone looking at the page.
Specific Challenges for LMT Manufacturers
LMT manufacturers face unique hurdles that differ from large EV manufacturers:
Supply Chain Complexity
Many e-bike and e-scooter manufacturers source their batteries as finished purchased parts from Asia (China, Vietnam, Taiwan). They don't produce battery cells themselves, yet must still provide complete battery passport data. This requires close collaboration with battery suppliers who are often not prepared for EU regulation.
Missing Supplier Data
Typical data gaps with purchased LMT batteries:
- Exact material composition of cathode/anode
- Carbon footprint data per kWh
- Origin of critical raw materials (cobalt, lithium)
- Due diligence reports and audit results
No Internal Compliance Team
While BMW or CATL have dedicated regulatory teams, many LMT manufacturers lack this expertise. Tools like DPP Hero are specifically designed to enable data entry without regulatory background, with guided steps following DIN SPEC 99100.
Carbon Footprint for LMT Batteries
Under Article 7(1) of the EU Battery Regulation, the carbon footprint declaration for LMT batteries applies from 18 August 2028 or 18 months after the delegated methodology act and the implementing format act enter into force, whichever is the later. For electric vehicle batteries the date is 18 February 2025 or twelve months after both acts enter into force, and for rechargeable industrial batteries above 2 kWh, excluding those with external storage only, 18 February 2026 or 18 months after both acts enter into force, in each case whichever is the later.
How far these acts have progressed for electric vehicle and industrial batteries is shown on our overview What the EU still has to deliver. The Commission’s nonbinding guidance, version 3.2 of 19 October 2026, lists the carbon footprint declaration as “Not to be filled/displayed as of February 2027”, because its format is still to be set by an upcoming implementing act. You can still prepare now:
- Have the carbon footprint per kWh calculated
- Perform the calculation along the essential elements of Annex II, which the delegated act under Article 7(1) will turn into the binding method
- Document the result in the battery passport
For many LMT manufacturers, this is the most challenging requirement, as LCA calculations (Life Cycle Assessment) require specialized expertise. Learn more in our article Carbon Footprint in the Battery Passport.
Practical Steps for LMT Manufacturers
- Contact battery suppliers: Request material and CO₂ data from your cell suppliers now. The earlier you ask, the more time suppliers have to prepare.
- Understand the data standard: DIN SPEC 99100 defines the data structure across seven categories. Tools like DPP Hero have the entire structure already built in, you can start entering data immediately without needing to interpret the specification yourself.
- Conduct a data audit: What data do you already have? What's missing? Our Battery Passport Checklist guides you through the process.
- Set up a tool: Choose a tool that supports the DIN SPEC 99100 data structure and suits your product volume. With DPP Hero, one published passport is free, and all plans are listed on our pricing page.
- Start a pilot: Create a battery passport for your best-selling e-bike or e-scooter model as a test run. How this works step by step is shown on our page create a battery passport.
Five questions for your battery supplier
Much of the passport data sits with whoever makes the cells and the battery. These five questions clarify early what you need from them.
- What cell chemistry do you use, and will you supply the data for it? Without the cell maker’s figures, the passport lacks the material composition and the critical raw materials.
- When will a carbon footprint declaration be required for your batteries? Not on 18 February 2027. The Commission’s nonbinding guidance (version 3.2 of 19 October 2026) does not foresee the declaration for February 2027, because its format still has to be set by an implementing act. Article 7(1) names 18 August 2028 for LMT batteries, or 18 months after the relevant acts enter into force, whichever is later. A life cycle assessment (LCA, a calculation across the whole life of the battery) still needs lead time, so the question pays off now.
- Who places the battery on the EU market, you or us? This decides who takes care of the passport (Article 77(4)). If you place a battery from a third country on the EU market, that is you.
- Is there a GTIN per model and a unique serial number per battery? Every battery needs its own identifier linked to the QR code (Article 77(3)). For a GS1 identifier, the GTIN and serial number form that basis together, but the Regulation also allows equivalent standards. Clarify the numbering logic early.
- From which delivery date does our order need the passport? What matters is when the battery is placed on the market or put into service. Anything newly placed on the market from 18 February 2027 needs the passport (Article 77(1)).
What Applies to Importers and Distributors?
If you import e-bikes or e-scooters (e.g., from China) and sell them in the EU, you are the responsible economic operator, not the Asian manufacturer. This means:
- You must ensure a battery passport exists
- You are responsible for data accuracy
- You must affix the QR code to the battery or packaging, ideally based on the GS1 Digital Link standard
Negotiate with your suppliers now to include battery passport data in supply contracts. From 18 February 2027, every battery you newly place on the EU market needs a battery passport. What else importers have to check is set out on our page battery passport for importers.
What has to go on the battery besides the QR code
The QR code is the best known marking, but not the only one. Annex VI Part A of the Regulation sets out what goes on the label:
- information identifying the manufacturer, the battery category and the identification of the battery
- place and date of manufacture (month and year)
- weight and capacity
- chemistry and hazardous substances present, other than mercury, cadmium or lead
- the extinguishing agent to be used
- critical raw materials present above 0.1 % by weight
Under Article 13(1), this label obligation applies from the later of two dates: 18 August 2026 or 18 months after the related implementing act enters into force. We track the status of that act on our page Battery passport: what the EU still has to deliver.
The symbols and their own deadlines
Two markings do not depend on the passport and have dates of their own. The separate collection symbol under Annex VI Part B has applied to all batteries since 18 August 2025 (Article 13(4)). If the battery contains more than 0.002 % cadmium or more than 0.004 % lead, the chemical symbol Cd or Pb is added (Article 13(5)). The QR code itself becomes mandatory on 18 February 2027 (Article 13(6)). If you only redesign your labels for the passport, you are already late for the collection symbol.
Registration with stiftung ear before the first battery ships
Alongside the Regulation, German law applies: the Battery Act Implementation Act (BattDG). Anyone making batteries available in Germany for the first time registers beforehand with stiftung ear, per brand and battery category (section 5(1) sentence 1 BattDG). Only a producer that is properly registered may make batteries available (section 4(1)), and distributors may not make available batteries of producers that are not properly registered (section 4(3)). Once all required information has been submitted, the registration is generally deemed granted after twelve weeks (section 5(1) sentence 4).
Producers without an establishment in Germany appoint an authorized representative for this (section 40(2)). On top of that comes participation in a producer responsibility organisation. Without it, the authority may revoke the registration (section 33(1)).
Replaceability and spare batteries: what Article 11 requires
Alongside the passport, the Battery Regulation sets a rule that often matters more in daily practice: Article 11 requires the battery of a light means of transport to remain replaceable. Paragraph 5 is explicit. Anyone placing a product with a built-in LMT battery on the market must ensure that this battery and the individual cells within the battery pack can be readily removed and replaced by independent professionals at any time during the product's lifetime. Not only by the manufacturer, and not only during the warranty period.
What “readily replaceable” means follows in paragraph 6: once removed, the battery must be replaceable by another compatible battery without impairing the functioning, the performance or the safety of the vehicle. Paragraph 8 closes the loop from the other side: software must not be used to make replacement with a compatible battery more difficult. Firmware that locks out third-party packs does not square with that.
The provision with the biggest consequences for spare-part planning is paragraph 7. After the last unit of an equipment model has been placed on the market, the matching battery must remain available as a spare part for at least five years, at a reasonable and non-discriminatory price, for independent professionals and end users alike. Sell the last unit of an e-bike model in 2027 and you must be able to supply its battery until 2032 at the earliest.
Under paragraph 9 the Commission publishes guidelines for the harmonised application of this article. Until they arrive, the wording in the Official Journal is what counts.
Condition data in the passport, and who keeps it up after the sale
An e-bike battery is not sold and then forgotten. Under Annex XIII point 4, the passport also holds the entries for the individual battery: state of health, cycle count, negative events. These are not part of the public tier; they are reserved for those who demonstrate a legitimate interest. The underlying data exists anyway: under Article 14(1) the parameters for state of health and expected lifetime have had to sit in the battery management system of LMT batteries since 18 August 2024, and paragraph 2 requires read access to be granted at any time and without discrimination to lawful purchasers and waste operators.
Who keeps the passport current is set out in Article 77(4): the economic operator who placed the battery on the market. They may authorise others in writing to act on their behalf, the bicycle manufacturer or a fleet operator for instance. The responsibility stays with them, even when the pack is with its third owner.
When the life stage changes, the duty moves. If the pack is prepared for re-use, repurposed or remanufactured, paragraph 7 places it on whoever puts it back on the market, and the battery receives a new passport linked to the old one. For the second-hand market that means: refurbish and resell, and you become responsible for the passport. Once it becomes waste, the duty passes to the producer, the producer responsibility organisation or the appointed waste operator.
What the passport is good for when things go wrong: recalls and counterfeits
The mandatory part is one reason for the passport. The other shows when something goes wrong. Article 38(9) requires producers who have reason to believe that a battery they placed on the market does not meet the requirements to take corrective measures immediately, to withdraw it from the market or to recall it. Where the battery presents a risk, the market surveillance authority of the member state concerned must also be informed immediately.
This is where serialisation pays off. Because every unit carries its own identifier, a recall can be limited to the batch concerned or even to individual units, instead of pulling a whole model line. Document at model level only and you do not have that choice.
The second benefit is telling the original from the copy. The passport hangs on an identifier issued by the producer and held in the registry; a copy without a valid identifier shows up on scanning. For this, Article 78(h) expressly requires the passport to offer a high level of security and to avoid fraud. That is no guarantee against counterfeiting, but it is a hurdle that was not there before.
Frequently Asked Questions
Does my e-bike need a battery passport?
Yes, if the e-bike is first placed on the EU market from 18 February 2027. The mandate applies to all LMT batteries regardless of capacity.
Does the battery passport also apply to replaceable e-bike batteries?
Yes. Every individual battery needs its own battery passport with a unique serial number and QR code, including replacement batteries sold separately.
What if my battery supplier can't provide data?
Then you should switch suppliers or contractually obligate them to provide data. From 18 February 2027, every battery you newly place on the EU market needs a complete battery passport. The sooner you inform your suppliers, the better.
Are e-bike batteries under 2 kWh affected?
Yes. The 2 kWh threshold only applies to industrial batteries. LMT batteries fall under the battery passport mandate regardless of capacity. A 400 Wh e-bike battery needs a battery passport just as much as a 1 kWh e-scooter battery.
Are there differences between pedelec and S-pedelec batteries?
Not for the battery passport: both are LMT batteries with the same requirements. Only the classification of the vehicle differs. A pedelec with a maximum continuous rated power of 250 W whose motor only assists while pedaling, is progressively reduced and cuts off before 25 km/h does not need EU type approval. An S-pedelec also assists above 25 km/h and therefore belongs to category L1e-B. This has no impact on battery passport obligations.
