What Are LMT Batteries?
LMT stands for Light Means of Transport. The EU Battery Regulation (EU) 2023/1542 defines LMT batteries as batteries specifically designed to power vehicles in categories L1e through L7e. In practice, this includes:
- E-bikes and pedelecs (category L1e-A)
- E-scooters and electric kick scooters (category L1e-B)
- E-mopeds and e-motorcycles (categories L1e through L7e)
- Electric wheelchairs and mobility scooters
- Light electric utility vehicles (e.g., registered e-cargo bikes)
Crucially: classification as an LMT battery depends not on capacity but on intended use. A 500 Wh battery in an e-bike is an LMT battery; the same battery in a vacuum cleaner would be a portable battery.
Why LMT Manufacturers Must Act Now
The European market for e-bikes and e-scooters is growing rapidly: over 5 million e-bikes were sold in the EU in 2024, with numbers rising. 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.
Timeline: What Deadlines Apply to LMT Batteries?
LMT batteries share some deadlines with EV and industrial batteries, while others are later:
- February 18, 2027: Digital battery passport becomes mandatory — including for LMT batteries
- February 18, 2027: Supply chain due diligence obligations
- August 18, 2031: Recycled content minimum quotas for EV and industrial batteries (not yet for LMT)
- 2033: Recycled content obligations also for LMT batteries
- August 18, 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.
What Data Must LMT Manufacturers Capture?
LMT batteries are subject to the same seven data categories of DIN DKE 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?
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
The carbon footprint declaration becomes mandatory for LMT batteries from February 2028 (one year later than for EV and industrial batteries). Manufacturers must:
- Have the carbon footprint per kWh calculated
- Perform the calculation according to EU methods (Product Environmental Footprint Category Rules)
- 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.
- Start a pilot: Create a battery passport for your best-selling e-bike or e-scooter model as a test run.
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
Negotiate with your suppliers now to include battery passport data in supply contracts. From 2027, you simply cannot legally sell products without a battery passport in the EU.
Frequently Asked Questions
Does my e-bike need a battery passport?
Yes, if the e-bike is first placed on the EU market from February 18, 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 2027, you cannot legally sell batteries in the EU without complete passport data. 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 from a regulatory standpoint — both fall under the same requirements as LMT batteries. The only difference is in vehicle categories (L1e-A vs. L1e-B), which has no impact on battery passport obligations.