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:
What LMT manufacturers should do now is summarized on the battery passport for e-bike and LMT batteries page.
- E-bikes and pedelecs (category L1e-A)
- 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-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 does not depend on capacity. Article 3(1)(11) requires a battery that is sealed, weighs 25 kg or less and is designed to provide traction power for light wheeled vehicles, including type-approved vehicles of category L. 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.
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.
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.
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?
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.
How the legitimate interest is to be proven is left to an implementing act under Article 77(9), still outstanding. 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
Article 7(1) of the EU Battery Regulation ties the carbon footprint declaration for LMT batteries to 18 August 2028 or 18 months after the delegated methodology act and the implementing format act enter into force, whichever is the latest. Neither act had been adopted as of 20 August 2026, so the fixed dates for electric vehicle batteries (18 February 2025) and for rechargeable industrial batteries (18 February 2026) have passed without triggering the obligation. As long as the two acts are missing, there is nothing mandatory to enter in the carbon footprint section of the battery passport, not even in February 2027. Prepare the data anyway, because the clock starts on the day the acts enter into force:
- 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.
- 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, ideally based on the GS1 Digital Link standard
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.
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 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.
