Do e-bike batteries need a battery passport?

This is the confusion that catches the most brands. The headlines about the EU battery passport talk about electric vehicles and gigafactories, so a company shipping e-bikes or e-scooters assumes it is watching someone else's problem. It is not. Light means of transport batteries are named as an in-scope category, and because they have no 2 kWh floor, even modest packs are covered.

Why e-bike batteries are in scope: the LMT category

Regulation (EU) 2023/1542 sorts every battery into categories, and the passport obligation in Article 77 applies to three of them: electric vehicle batteries, LMT batteries, and industrial batteries with a capacity above 2 kWh. An "LMT battery" is defined in Article 2 as a battery that provides electric power for the traction of wheeled vehicles that can be powered by the electric motor alone or by a combination of motor and human power — e-bikes, e-scooters, e-mopeds and similar light electric vehicles.

That definition is the whole ballgame for a light-electric-vehicle brand. If your product moves a person on wheels using a battery, the pack driving it is almost certainly an LMT battery, and LMT batteries carry the passport.

The threshold trap: "but our pack is under 2 kWh"

The most common way a brand talks itself out of the rule is the 2 kWh line. That threshold is real — but it applies to industrial batteries, not LMT ones. A typical e-bike battery sits somewhere around 0.3 to 0.8 kWh, comfortably under 2 kWh, and none of that matters. LMT is its own category with its own passport obligation, and there is no minimum size. Reading the industrial threshold across onto e-bike packs is exactly the mistake the regulation's category structure is designed to prevent.

Who has to produce it — and why it is probably you

The passport is owned by the economic operator who places the battery on the EU market or puts it into service (Article 77, read with the definitions in Article 2). For most LEV brands, packs are made overseas — often in Asia — and shipped in. The overseas cell or pack maker is outside the EU and outside the reach of the obligation; the party that first supplies the battery on the EU market is the importer or the brand itself. That makes you the operator responsible for the passport's accuracy and upkeep, even though you did not build the cells.

The practical consequence: you cannot populate the passport from your own records. Cell chemistry, material composition, carbon footprint and performance data all live with your supplier, so the long-lead-time task is getting that data flowing before February 2027 — not building the QR code, which is the easy part.

What actually has to be behind the QR code

The passport resolves, via a QR code on the battery or its packaging, to a structured record. Article 77 and Annex XIII group the required content into identity data, technical and performance characteristics, sustainability and carbon-footprint information, and circularity and supply-chain data. For an e-bike brand, the fields you can fill yourself are few; most must come from the pack supplier. That is why the supplier request is the thing to start now.

This guide is general information about Regulation (EU) 2023/1542, not legal advice. Scope and responsibility turn on your specific product and role, and the passport's technical specification is still being finalised through a pending delegated act and standards (see the honesty note below). Confirm your position with qualified counsel before you rely on it.

Frequently asked questions