Does the battery in an e-bike or scooter need a battery passport?
Yes, as a battery for light means of transport, it falls under the digital product passport requirement
The battery of an e-bike, e-scooter or scooter falls in most cases under the category "battery for light means of transport" (LMT battery) from the Battery Regulation. For this category, the obligation to make available a digital battery passport applies. This means that the battery in an e-bike, an electric scooter or a scooter used for propulsion is in principle required to have a passport as soon as the obligation comes into effect — regardless of the brand, the power or whether the battery is sold separately or already installed in the vehicle.
Which batteries this applies to, and which do not
An LMT battery is, in short, a battery designed to propel a vehicle that is controlled by or ridden by a person, such as an e-bike, an electric scooter, an electric scooter or a similar light means of transport. This distinguishes itself from an EV battery, which is intended for traction in a car or other motor vehicle, and from an industrial battery, which for example is installed in machines, tools or stationary storage. Both other categories also fall under the digital product passport requirement, but on the basis of a different definition.
An important difference from industrial batteries: for those, the digital product passport requirement only applies above a capacity of 2 kWh. For LMT batteries, this threshold does not exist. An e-bike battery of 400 or 500 Wh — by far the most common capacity — therefore falls just as much under the obligation as a large battery pack of a cargo bike or a heavy electric scooter. Anyone who thinks that a small battery will escape because it is below 2 kWh is reasoning from the wrong category.
What falls outside this subject: portable batteries that do not have a propulsion function, such as the battery of a bicycle lamp, a power bank or a tool that does not itself move. Also batteries specifically designed for the automotive or machinery industry (EV and industrial batteries) follow their own trajectory, even though the digital product passport requirement appears the same on paper.
From 18 February 2027, until then no legal digital product passport requirement
The obligation to have a battery digital product passport comes into effect on 18 February 2027. Until that date, there is no legal requirement for LMT batteries to have a passport. This does not mean that nothing needs to be done until then: the data that will have to be in the passport — on composition, origin, performance and end of life — generally do not come from nowhere. They must be collected from the manufacturer or, when importing from outside the EU, from the importer who takes responsibility. Anyone who waits until just before the date runs the risk that this data will not be ready in time.
How this is handled in practice
The first step is to check whether the battery indeed falls under the definition of an LMT battery: if it is designed to propel a vehicle with a rider, such as an e-bike, scooter or scooter, this is usually the case. Next, it is important to know who in the chain is responsible for providing the data — this is usually the manufacturer, or in the case of products from outside the EU, the importer who places the product on the European market. Then it comes down to collecting the underlying information: material composition, origin of raw materials, performance data and information on reuse and recycling. This data forms the basis of the passport. Finally, the passport must be linked to a QR code or similar data carrier on the battery itself, so that the information can be retrieved by the entire chain — from trader to recycler — and the passport must remain accessible for a longer period.
Where this follows from: Article 1, Article 3 and Article 77
The scope of the regulation is set out in Article 1 of Regulation (EU) 2023/1542 (Battery Regulation); it specifies which categories of batteries the regulation applies to, including batteries for light means of transport. The definition of an LMT battery, and the distinction with an EV battery and an industrial battery, is set out in Article 3 of the same regulation. The obligation to make a digital battery passport available for these categories, including the link to a data carrier, is laid down in Article 77.
What to do now
Anyone who imports, trades in or installs e-bike, e-scooter or scooter batteries should already check which data on the battery are available from the manufacturer, and which are still missing. Batpas.eu compiles the passport on the basis of that data, hosts it for the required period and supplies the QR data carrier — so that this process does not have to start only shortly before 18 February 2027.
What this is based on
- Regulation (EU) 2023/1542, Article 1 (subject matter and scope) and Article 3 (definitions)
- Regulation (EU) 2023/1542, Article 77 (battery passport)
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
Yes — in most cases, the battery of an e-bike or an electric scooter falls under the obligation to provide a battery passport. These batteries are designated in Regulation (EU) 2023/1542 (Battery Regulation), article 3, as batteries for light means of transport, also known as LMT batteries. For this category, the passport obligation under article 77 of the same regulation applies. What an LMT battery precisely entails and where the boundary lies with other categories is set out in what is a light electric vehicle battery (LMT battery)?
The underlying logic is simple: a battery that is built in or intended for the propulsion of a wheeled vehicle such as an e-bike, electric scooter or scooter falls within the scope that article 1 of the regulation describes. That scope is broadly defined and distinguishes itself from, for example, portable batteries (such as loose AA batteries or power banks) and industrial batteries. An overview of the categories that the regulation distinguishes is available on which batteries fall under the battery regulation?
What is expected of you
Determining whether the battery is actually an LMT battery
Not every battery in an e-bike or scooter is automatically an LMT battery within the meaning of the regulation. The classification depends on the intended use and technical characteristics of the battery, not on the appearance of the vehicle. For a company with between 10 and 100 employees, this means that the first step consists of reviewing the product range: which models contain a battery that falls under this definition, and which may differ (for example because it is a stationary storage or backup battery). Uncertainty about the classification of a specific product range can be checked against the criteria on does the battery passport apply to my batteries?
Determining who in the supply chain draws up the passport
The obligation under article 77 lies with the party that places the battery on the market. For an e-bike importer who imports ready-made bicycles with built-in battery, that role often falls on the importer themselves, even if the battery is manufactured by another manufacturer. In the case of assembly in-country, or when purchasing private label products, it is important to clarify who provides which data and who bears ultimate responsibility for the passport. This question is particularly relevant for products in which the battery is part of a larger whole, as set out in the battery is built into my product — who then creates the passport?
Collecting and submitting the correct data
A passport is only as good as the data it contains: chemical composition, capacity, origin of raw materials, repair and disassembly information, and the like. For an importer, this practically means that the manufacturer's technical documentation must be complete and must be requested at an early stage, not only when a delivery is already on the way. For companies that assemble batteries themselves from purchased cells, the responsibility for complete and correct data lies even more directly with the company itself.
Ensuring the QR data carrier is on the product
The passport must be accessible via a QR code on or near the battery. For e-bikes and scooters, this means that in the production process or during assembly there is a moment when this code is actually applied to the product or battery, and that this code remains readable and functional throughout the product's life.
Ensuring the passport remains available for the required period
A passport is not a one-time action; the data must be accessible over a long period of time, even when an importer stops a particular model or changes supplier. This requires a structural solution for hosting and management, rather than a document that gets lost at the first system change.
Where things go wrong in practice
An importer of e-bikes assumes that the passport is a task of the Asian factory, while the regulation places the obligation on the person who places the product on the market in the EU — often the importer themselves.
A dealer sells scooters under its own brand name but with a purchased, generic battery, and only discovers late that the battery supplier cannot provide the technical underlying data required for a complete battery passport.
For a product line with multiple battery variants (for example, different capacities for the same bicycle model), the same battery passport is used for all variants, while the underlying technical data differ per variant.
A company sets up the QR data carrier only at the final step before shipment, so that if there is a change in the battery specification, the code no longer matches the battery actually delivered.
A machine builder that manufactures light electric vehicles for business use incorrectly assumes that the battery passport applies only to the consumer market e-bikes segment, and not to business or B2B applications.
What you can record
- An overview of all product types with batteries, with for each type an assessment of whether it qualifies as an LMT battery.
- Agreements with suppliers on which technical data are provided as standard with each delivery.
- An internal document setting out who in the supply chain (manufacturer, importer, assembler) is responsible for compiling the battery passport.
- A work instruction for affixing the QR data carrier during production or assembly, including a check on readability.
- An archive of previous battery passports and associated technical documentation, so that changes in battery specifications remain traceable.
- A checkpoint at new model years or battery variants, to verify that the existing battery passport still aligns with the actual specifications.
For companies that carry product types other than e-bikes or scooters, for example portable batteries or stationary storage, the distinction is relevant to the question of which obligation applies; see do portable batteries also need a battery passport? and does the battery passport apply to a home battery or stationary storage?
This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.