Battery passport for e-bikes
& light means of transport

When a battery counts as an LMT battery

The regulation calls the category “light means of transport battery”, LMT battery for short. The legal definition in Article 3 sets four conditions. All four have to apply.

The four features of the definition

The battery is sealed, weighs 25 kg or less, is specifically designed to provide traction to wheeled vehicles that can be powered by electric motor alone or by a combination of motor and human power, and it is not an electric vehicle battery. Type-approved vehicles of category L under Regulation (EU) No 168/2013 are expressly included.

Why the 25 kg decide

Weight is not a side condition but the line to the electric vehicle battery. If an e-motorcycle battery weighs more than 25 kg, it falls out of the LMT category. It is then treated as an electric vehicle battery. For the passport duty that changes nothing. For the requirements on removal and spare parts it changes a lot.

What happens to the battery passport after the sale

An e-bike battery stays in use for years, and its characteristics change considerably. That is why the regulation holds a second data set on the individual battery alongside the model data. Those are the dynamic values, above all the state of health and the number of full charging cycles. For manufacturers that means: the passport is not finished at delivery. That is where its longer part begins.

Which values an LMT battery has to supply

Since 18 August 2024 Article 14(1) requires current parameters from Annex VII in the battery management system. For LMT batteries Part A names remaining capacity. Plus, where possible, remaining power capability and round trip efficiency. Plus the evolution of self-discharge and, where possible, ohmic resistance. The certified state of health SOCE expressly applies to electric vehicle batteries only, not to your battery. Part B adds for the lifetime the date of manufacture plus energy and capacity throughput. Plus tracking of harmful events such as deep discharges or charging at extreme temperatures. And the number of full equivalent cycles.

Who adds them during service

The duty rests with the economic operator placing the battery on the market. For imported batteries that is the importer, not the manufacturer in the country of origin. Under Article 77(4) this operator ensures the data is accurate, complete and up to date. They may authorize others in writing to act on their behalf. That is the practical route in the trade. The diagnostic tool reads the values during service, the authorized shop enters them. Responsibility stays with the economic operator. Fail to arrange this chain and the passport stops being accurate at the first service appointment.

What the buyer gets out of it

Article 14(2) gives every lawful acquirer read access to these parameters, at any time and without discrimination. The regulation names the purpose expressly: assess residual value and remaining lifetime and facilitate preparation for re-use. For the second-hand market that is the real change. Until now the condition of a used battery was a matter of negotiation. Paragraph 3 additionally requires a reset function for the software in the battery management system. Shops remanufacturing a battery can then load their own software. For impairments caused by that new software the original producer is then not liable. The regulation does not say how many fields that is. Annex XIII lists the entries, Article 77 makes them mandatory. The Commission guidance “Digital Batteries Passport, data points by category” sorts them. It holds 71 data points and classes each one. For LMT batteries 49 of them are mandatory. Figures like “90 mandatory fields” circulating in the market do not match that. Two further blocks apply only later. Minimum recycled content shares apply from 18 August 2031 and in a second stage from 18 August 2036 (Article 8(2) and (3)). And the carbon duties are not triggered, because the delegated methodology act under Article 7(1) is missing.

Removability, cells and spare parts

Article 11 sets stricter requirements for LMT batteries than for portable ones. Whoever places products with a built-in LMT battery on the market carries them. Whether they are manufacturer or importer makes no difference.

Individual cells must be replaceable too

The difference from portable batteries sits in paragraph 1 subparagraph 2: there the duty expressly does “not apply to individual cells or other parts of a battery, but only to the whole battery”. For LMT batteries paragraph 5 draws the line one level lower and names the cells in the battery pack separately. For design that means a permanently bonded cell assembly does not meet the requirement, even if the housing opens.

What readily replaceable means

More telling than the wording is which exemptions do NOT apply here. The exemptions in paragraph 2, for example for splash-proof appliances, hang off paragraph 1 and therefore cover portable batteries only. The same goes for paragraph 3, which protects continuity of power supply. For LMT batteries the requirement in paragraph 5 stands, with no fallback.

Five years of spare part availability

The reference point for the five-year period is not the individual product but the last unit of an equipment model. A model built for three years therefore ties up spare part supply for roughly eight years. That is a planning requirement for range and stock, not a design question. How the requirements are to be applied consistently is something the Commission is to set out in guidelines under paragraph 9.

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 lists the entries for the label. Those are data identifying the manufacturer and the battery category. Plus place and date of manufacture, weight and capacity. Plus the chemical composition and hazardous substances contained. And finally the extinguishing agent to use and critical raw materials above 0.1 percent by weight.

The symbols and their own deadlines

Two symbols do not hang on the passport and carry dates of their own. The separate collection symbol, the crossed-out wheeled bin under Annex VI Part B, has applied to all batteries since 18 August 2025. The chemical symbol is added where the battery contains more than 0.002 percent cadmium or more than 0.004 percent lead. The QR code itself follows on 18 February 2027. Redesign your labels only for the passport and you have already missed the collection symbol date.

Registration and take-back before the first battery ships

Alongside the regulation stands German law, since 2025 the Battery Act Implementation Act. Anyone first making batteries available in Germany registers with stiftung ear beforehand. Only a producer that is properly registered may make batteries available (section 4(1) BattDG); after twelve weeks without a decision the registration counts as granted by operation of law (section 5(1) sentence 4). Manufacturers without a German establishment appoint an authorized representative for it. On top comes participation in an approved producer responsibility organisation. Fail to enter your volumes there and the authority may revoke the registration (section 33(1)). Registration runs per brand and per battery category. How far the sector has come was visible at the trade fair: Eurobike and the battery passport. How the battery passport fits into the Ecodesign Regulation is explained on digital product passport.