Battery passport for e-bike batteries

Batteries for e-bikes, pedelecs, e-scooters and e-mopeds are LMT batteries ("light means of transport") as long as they are sealed and weigh 25 kg or less (Art. 3(1), point 11). Every LMT battery placed on the EU market from 18 Feb 2027 needs a battery passport (Art. 77(1)). Unlike industrial batteries, there is no capacity threshold: even a small scooter battery needs a passport.

Who has to create the passport?

The responsible party is the economic operator placing the battery on the market, i.e. making it available on the EU market for the first time (Art. 77(4)). It may authorise others in writing to maintain the passport on its behalf. In practice:

• You build batteries in the EU or have them built under your brand: you are the manufacturer and create the passport.
• You import e-bikes or batteries from a non-EU country, for example China: you are the importer and create the passport, even if the battery is built into the frame.
• You buy batteries from a system supplier that has already placed them on the EU market and fit them to your bikes: the passport usually comes from the system supplier. Get this confirmed in writing.
• You only resell bikes or batteries: you are a distributor and do not create a passport, but from 18 Feb 2027 you may no longer offer batteries that require a passport without a QR code and passport.

Which batteries are affected

• Only batteries placed on the EU market for the first time from 18 Feb 2027. Stock that was already on the EU market before does not need a passport retroactively.
• Replacement batteries just like batteries sold with the bike. Every single battery gets its own passport with its own serial number.
• Remanufactured batteries: whoever remanufactures a used battery (assessing all cells, replacing cells, at least 90 % of the original capacity) and sells it again needs a new passport linked to the old one (Art. 77(7), Art. 3(1), point 32).

What goes into the passport

The passport contains data on the battery model and on the individual battery (Annex XIII). For the start in February 2027 this mainly means:

• Manufacturer, model, battery category, place and date of manufacture, weight and chemistry (e.g. NMC or LFP)
• Hazardous substances, critical raw materials and suitable extinguishing agent
• Performance and durability values: nominal voltage, capacity, power, expected lifetime in cycles, efficiency, internal resistance, permitted temperature range
• EU declaration of conformity, dismantling and safety information, sources of spare parts
• Per battery: serial number, status (new, reused, remanufactured) and state-of-health information

You have had to state the performance values in the documentation accompanying the battery since 18 Aug 2024 (Art. 10(1)). If you have that documentation, you already have a large part of the passport data.

Further obligations from February 2027

• QR code on the battery that leads to the passport (Art. 13(6)).
• Replaceability: whoever places e-bikes on the market must ensure that the battery and the individual cells in the battery pack can be readily removed and replaced by independent professionals (Art. 11(5)).
• Spare parts: the battery must remain available as a spare part at a reasonable price for at least five years after the last unit of a model has been placed on the market (Art. 11(7)).
• No software locks against compatible replacement batteries or cells (Art. 11(8)).

Already in force: the battery management system must store state-of-health data and give the buyer and workshops acting on their behalf read access to it (Art. 14, since 18 Aug 2024).

How to proceed

1. List every battery model you will sell on the EU market for the first time after 17 Feb 2027, including replacement batteries.
2. Clarify for each model who places the battery on the market: you or your supplier.
3. Request the Annex XIII data from the manufacturer. The importer checklist shows which fields you need.
4. Create the passport per model and add the serial number of each battery, easiest via CSV import.
5. Have the QR code printed on the battery or label. Plan printing well before February 2027.