does the battery passport also apply if the battery is removable from the bicycle

Removable or permanently installed, the battery remains an LMT battery

Yes, an e-bike battery that can be removed from the frame via a separate charging port is subject to the same rules as a battery that is permanently installed in the frame. The regulation looks at the type of battery and not at the way it is attached to the vehicle. A battery designed to power electric bicycles, electric cargo bicycles or scooters falls under the category of battery for light electric vehicles — in short LMT battery — as defined in Article 3 of Regulation (EU) 2023/1542 (batteries regulation), Article 77. Whether that battery comes out of the frame with a click, can be removed with a key, or cannot be removed at all without tools, does not change that classification.

What this applies to, and what it does not

This explanation is about the battery itself, not about the bicycle or scooter in which it is used. The vehicle as a whole is not a battery and therefore does not receive a battery passport either — that passport belongs with the battery. This means that an importer who puts both bicycles and separate replacement batteries on the market must ask the same question for both: is this an LMT battery, and if so, then the passport requirement applies to that battery, regardless of whether it was sold as an original part with the bicycle or separately as a replacement battery on the shelf. For the classification it also does not matter whether the battery is intended to be swapped on the go (for example in bike-sharing scooters) or to be charged at home on the wall while the bicycle is in the shed: as long as the battery is designed to power a light electric vehicle, it counts as an LMT battery. What falls outside this scope is the battery that is rechargeable but is not intended to power a vehicle — such a distinction is described in what a battery for light electric vehicles (LMT battery) exactly means.

Another point of demarcation: this concerns the battery that powers the bicycle or scooter, not a possible extra power bank that is supplied separately to charge a telephone during the ride. Such a power bank falls under a different category and requires its own assessment, whereby for example the rules for portable batteries and the passport may be relevant.

Mandatory from 18 February 2027, not yet

The battery passport requirement will apply from 18 February 2027. At present, with 181 days still to go, there is no legal obligation to have a digital battery passport yet, but the other requirements from the batteries regulation — such as requirements for CE marking, information on composition and due diligence in the supply chain — may already apply, depending on the part of the regulation. For the precise effective date and which obligations apply before that anyway, the page on when the battery passport becomes mandatory provides a fuller picture. Until 18 February 2027, there is thus room to prepare the passport, but no exemption that continues after that: the obligation applies to batteries placed on the market after that date.

What this concretely means for those who import or sell e-bike batteries

Anyone who imports or places e-bike or scooter batteries on the market would do well to first establish whether the battery falls within the definition of LMT battery — that is the first step, and it is independent of how the battery is attached to the vehicle. The next step is to establish whether the battery is sold separately (as a replacement battery, for example) or is supplied as standard with the bicycle or scooter: in both cases, the responsibility for the passport generally lies with the party that places the battery on the market, not with the manufacturer of the vehicle itself, unless it is the same party. When the battery is built into a larger device and is not traded separately, the question of who compiles the passport is somewhat different, and that situation is addressed on the page on what applies when the battery is in my product. For e-bike and scooter batteries that are available separately — as an original part or as a replacement — the next step is to determine which data must be included in the passport and who supplies it: the manufacturer in the country of origin, or the importer who first places the battery on the market in the EU. A more detailed explanation of this specific situation can be found in the question whether the battery of an electric bike or scooter requires a battery passport.

Where this follows from: Article 3 and Article 77

The qualification as an LMT battery follows from the definitions in Article 3 of Regulation (EU) 2023/1542 (Battery Regulation), Article 77, in which battery categories are distinguished on the basis of the use for which the battery is designed — not on the basis of the method of attachment to the vehicle. Article 1 of the same regulation describes the scope, which shows that the rules apply to batteries placed on the market in the Union, regardless of whether they are sold separately or as part of a larger product. The passport obligation itself, including the associated information requirements, is set out in Article 77 of Regulation (EU) 2023/1542 (Battery Regulation), Article 77.

What to do now

Anyone in doubt as to whether a specific battery falls within the definition of an LMT battery is well advised to first consult the definitions in Article 3 and to check whether the battery is designed to power a light means of transport. For a broader overview of which battery types fall under the regulation, the page on which batteries fall under the Battery Regulation provides a starting point, and for a concrete assessment of your own situation, the page does the battery passport apply to my batteries is a logical follow-up.

What this is based on

The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.

What you need to do concretely

What is expected of you

The question of whether a removable e-bike battery falls under the battery passport is not answered by looking at how the battery is attached, but by looking at the type of battery itself. A battery designed to assist muscles in powering a bicycle, scooter or other light means of transport falls under the category of LMT battery as defined in Article 3 of Regulation (EU) 2023/1542 (Battery Regulation). Whether that battery is held in place with a lock on the rear frame, is recessed into the frame tube, or can be pulled out with one hand to charge indoors, makes no difference to that qualification. What a battery for light means of transport (LMT battery) exactly is, is independent of the method of assembly.

Establishing that it is an LMT battery, not a portable battery

The distinction that matters in practice is not "fixed or removable", but "LMT or portable". A portable battery is intended for general use in consumer electronics and is not specifically built for traction in a light means of transport. An e-bike battery, even a removable one, is: it is designed and dimensioned to power a bicycle or scooter. For a company with 10 to 100 employees, this means that the classification of the product is not determined by the sales department or by the marketing text, but by the technical specifications of the battery. Anyone wishing to verify this for their own range will find the broader demarcation between categories in which batteries fall under the battery regulation?

Establishing whether your own role is that of manufacturer or importer

The obligation to have a battery passport prepared rests with the person who places the battery on the market in the EU. For an e-bike with a removable battery, this is usually the importer of the complete vehicle, or — if the battery is sold separately as a replacement part — the party that imports or places that individual battery on the market. For a company with 10 to 100 employees, this means that the question "who is responsible here" must be answered separately for each product line: an importer who imports complete bicycles and also sells replacement batteries can fulfil that role for both streams, each with its own passport obligation. See also on this does the battery passport apply to my batteries?

One passport per battery, not per bicycle

The battery passport belongs to the battery, not to the vehicle in which it is installed at the time of sale. This has practical consequences for a removable battery: if a bicycle is sold with a different battery than the one it was originally assembled with, or if a spare replacement battery enters the market separately, that battery needs its own passport — separate from what was originally delivered with the bicycle. For companies that sell both complete bicycles and spare batteries, this means that the administration must be able to demonstrate per battery serial number which passport belongs to it, not per bicycle model.

Apply QR code to or on the battery

Article 77 of the Battery Regulation stipulates that the passport can be consulted via a data carrier on the battery. For a fixed battery, this is straightforward: one sticker, one location. For a removable battery, the QR code logically goes on the battery itself, not on the bicycle frame — because the battery is the object that changes, is sold as a replacement part, or goes along separately in a second-hand sale. For a company that sells batteries as replacement parts, this means that every separately sold battery must already carry its own QR code upon delivery.

Where things go wrong in practice

The battery is regarded as "part of the bicycle", not as an independent product. In the administration, the passport is linked to the bicycle model, while the battery has its own life cycle: it is replaced, sold separately, or returned without the bicycle. As a result, a spare replacement battery lacks the passport that should have been there.

Replacement batteries from another channel do not receive a passport. An importer who brings bicycles in complete with a passport on the battery sometimes purchases replacement batteries from a different supplier. That replacement battery is then treated as "the same article as previously passported", while it is a new product placed on the market with its own passport obligation.

The QR code is affixed to the frame instead of to the battery. From a practical standpoint, that seems logical — the frame lasts longer than the battery — but the passport belongs to the battery. When the battery is replaced, the link no longer matches.

Doubt about the category holds up the entire approach. Some companies delay passport preparation because they are unsure whether their product is an LMT battery or a portable battery, while that question can usually be answered from their own technical specification.

With private label, the role of "who places on the market" is not established. An importer who has batteries manufactured under its own brand is the one who places the battery on the EU market — even if the factory in another country technically supplies the passport.

What you can record

The technical specification of the battery, which shows its intended use (traction in a light means of transport) — relevant to support the classification as an LMT battery.
An overview of which batteries are sold separately as replacement parts, separate from the batteries that only leave the facility mounted in a complete bicycle.
Recording of one's own role (manufacturer, importer, or neither) per product stream — complete vehicle versus spare replacement battery.
The serial number management by which it can be demonstrated which passport belongs to which individual battery, even after a battery replacement.
Agreements with the supplier of replacement batteries about who provides the data for the passport, especially with private label.
More background on building up the passport can be found in the battery of an electric bike or scooter and, for the broader context of the obligation, in what is changing with the new battery regulation?

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 2026-09-05. Is something incorrect? Let us know — corrections take priority.