Eurobike 2026
Battery passport for e-bike batteries

Exhibiting at a trade fair does not constitute placing on the market. What matters is when the battery is first made available on the EU market: if that happens on or after 18 February 2027, it needs a battery passport, even if the model was presented at Eurobike beforehand. Batteries placed on the market before the deadline do not need to be retrofitted.

Responsibility lies with the economic operator placing the battery on the EU market. Anyone making batteries or e-bikes with built-in batteries from a third country available on the EU market for the first time takes on these obligations themselves. More on the page Battery passport for importers.

The passport deadline is 18 February 2027. Data entry itself is manageable; what needs lead time are supplier inputs such as cell chemistry and carbon footprint. The carbon footprint declaration itself only falls due for LMT batteries on 18 August 2028, or 18 months after the relevant acts. That is exactly why it pays to clarify these questions at the booth.

Two of them bite earlier than the passport. Since 18 August 2025 all batteries carry the separate collection symbol under Annex VI Part B; it must cover at least 3 per cent of the largest side, capped at 5 by 5 centimetres, and at least 1.5 per cent of the surface for cylindrical cells. If a battery contains more than 0.002 per cent cadmium or more than 0.004 per cent lead, the chemical symbol goes underneath, at least a quarter of the size of the collection symbol. From 18 February 2027 the QR code is added, printed or engraved visibly, legibly and indelibly. If you are reissuing labels now, plan for these areas straight away.

The cut-off of 18 February 2027 falls before the 2027 season, not after it. Every LMT battery you place on the market from that day needs a passport; it does not apply retroactively to models placed on the market earlier. In practice this means the data for your 2027 models has to be in place before production starts, not before sales start. Between the first supplier inquiry and a complete data set there are usually weeks, not days.

Article 3(11) of the Battery Regulation sets three conditions: the battery is sealed, it weighs 25 kg or less, and it is specifically designed to supply electric power for the traction of wheeled vehicles that can be powered by the electric motor alone or by motor and muscle power combined. Type-approved vehicles of category L are expressly included. Above 25 kg the pack is no longer an LMT battery: under Article 3(14) it counts as an electric vehicle battery only if it is designed for the traction of hybrid or electric vehicles of category L; any other battery above 5 kg that is neither an LMT, electric vehicle nor starter battery counts as an industrial battery under Article 3(13). Capacity plays no part in this classification.

Article 77(2) splits the entries into three access levels. Publicly readable through the QR code is Annex XIII point 1. Points 2 and 3 are seen only by notified bodies, market surveillance authorities and the Commission. Points 2 and 4, including the entries for the individual battery, are reserved for persons with a legitimate interest, such as repairers, remanufacturers, second-life users and recyclers. Your competitors are not among them.

For LMT batteries this has applied since 18 August 2024. Under Article 14(1) the parameters for state of health and expected lifetime under Annex VII sit in the battery management system. Paragraph 2 requires read access, at any time and without discrimination. That covers lawful acquirers, independent operators and waste operators. The benefit shows at the end of the first life. Without solid condition data a battery can neither be resold seriously nor assessed for a second life.

No. Extended producer responsibility is organized nationally. Whoever first makes batteries available in a member state needs a producer registration there. They join the take-back scheme of that country. Delivering to Germany, France and the Netherlands means three registrations. The collection information is agreed per country. The battery passport does not replace this, it comes on top.

Both later than the passport duty, and for LMT batteries later again than for the large types. The carbon footprint declaration is not triggered yet and falls due for LMT batteries on 18 August 2028 at the earliest; the details are in the answer on timing above. For recycled content, Article 8 applies: from 18 August 2031 at least 16 percent cobalt, 85 percent lead, 6 percent lithium and 6 percent nickel, but only for industrial batteries above 2 kWh, electric vehicle and starter batteries. LMT batteries, meaning your e-bike packs, only come in from 18 August 2036, then at 26 percent cobalt, 85 percent lead, 12 percent lithium and 15 percent nickel. So for the passport duty on 18 February 2027 you need neither a carbon figure nor a recycled content share.