Does the battery passport apply to my batteries?

Three categories of batteries fall under the passport requirement

The battery passport applies to EV batteries, batteries for light means of transport (such as e-bikes, e-scooters and similar vehicles) and industrial batteries with a capacity above 2 kWh. This follows from Article 77 of Regulation (EU) 2023/1542 (battery regulation), read in conjunction with the definitions in Article 3 and the scope in Article 1. Anyone who imports, manufactures or places on the market batteries within one of these three categories must attach a digital passport to each battery. Batteries that fall outside these categories — such as small portable batteries like those in mobile phones, cameras or household appliances — are exempt from this specific requirement, even though those batteries may be subject to other provisions of the same regulation.

Which batteries this applies to — and which it does not

The passport requirement is linked to the type of battery and, for industrial batteries, to the capacity. An EV battery, intended for powering electric vehicles, falls under the scheme regardless of capacity. The same applies to batteries for light means of transport: the battery of an e-bike, an electric scooter or a comparable vehicle falls under this requirement because the regulation distinguishes this category in Article 3 as a separate type of battery from, for example, portable batteries. Industrial batteries — batteries intended for industrial use, for example in machinery, storage systems or business equipment — fall under the passport requirement only if the capacity is above 2 kWh. An industrial battery with a lower capacity falls outside this specific requirement.

What is often overlooked here: it is about the type and application of the battery, not about the sector of the undertaking using it. A machinery manufacturer that installs a battery pack of 3 kWh in its own equipment is subject to the same requirement as an importer placing ready-made batteries for light means of transport on the market. Conversely, a trader in small loose batteries for consumer electronics falls outside this regulation with that assortment, even though in terms of business activity it resembles battery trading that does fall under the passport requirement.

Mandatory from 18 February 2027

The passport requirement will come into force on 18 February 2027. Until that date, there is no legal obligation to hold a digital battery passport for the batteries in question, although preparing the necessary data and processes well in advance may be worthwhile — not because the law requires it at that point, but because compiling a complete passport usually requires more effort than a brief administrative action. Anyone placing batteries on the market between now and the effective date that fall within the three categories mentioned is therefore not yet subject to the passport requirement, but will be once the date is reached for batteries placed on the market at that time (or thereafter).

What this means for the approach

As a first step, it is useful to establish which category the battery falls into: EV battery, battery for a light means of transport, or industrial battery. For industrial batteries, the next step is to establish the capacity in kWh, because the threshold of 2 kWh determines whether the passport obligation applies. For batteries that clearly fall within one of the three categories, the logical next step is to inventory which data about the battery are already available — such as data on composition, origin, performance and lifespan — and which data are still missing. For batteries where doubt exists about the classification, for example in borderline cases of capacity or where a battery can be used both industrially and in a vehicle, it is advisable to consult the definitions in Article 3 of the Regulation itself, because the exact delimitation of concepts such as "industrial battery" and "battery for a light means of transport" is laid down there.

For those who establish that their own batteries fall under the passport obligation, the next practical question is who in the chain is responsible for providing and keeping the passport data current — the manufacturer, the importer, or a party engaged for that purpose. This determines who must collect which data and at what time.

Where this is stated: Article 77, 1 and 3

The obligation to have a digital battery passport is set out in Article 77 of Regulation (EU) 2023/1542 (the Battery Regulation). Which batteries fall under this is determined by the definitions of the different battery categories in Article 3 of the same Regulation, in combination with the delimitation of the scope in Article 1. For a precise reading of the definitions and exceptions, the official text of the Regulation is the appropriate source.

What to do now

Anyone wishing to know whether a specific battery falls under this obligation begins by establishing the type of battery and, for industrial batteries, the capacity in kWh, and compares this with the definitions in Article 3 of the Regulation. If doubt about the classification persists, the official text of Regulation (EU) 2023/1542 is the appropriate source to fall back on, for example via the link under this article.

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

The answer to this question depends on two things: the type of battery, and sometimes the capacity. For most companies in the e-bike, scooter and battery trade, the answer falls into one of three categories: EV batteries, batteries for light means of transport (LMT batteries), and industrial batteries above 2 kWh. Anyone placing one of these three on the market within the EU will be dealing with the battery passport. Which batteries fall under the Battery Regulation describes the full classification; here it is about what this concretely means for day-to-day business operations.

The regulation itself names the categories in Article 1 (subject matter and scope) and elaborates the definitions in Article 3 (definitions) of Regulation (EU) 2023/1542. The obligation for a passport is laid down in Article 77 of that regulation.

What is expected of you

Determine which category the battery falls into

Before anything can be organised, it must be clear which category a battery falls into. For an e-bike or scooter importer, this is usually an LMT battery — a battery designed for vehicles such as e-bikes, scooters and similar light means of transport. What is a battery for light means of transport (LMT battery) explains where that boundary exactly lies. For machinery manufacturers and industrial applications, the question is different: capacity often plays a role there. What does the 2 kWh threshold mean for industrial batteries is then the reference point. For a company with 10 to 100 employees, this means in practice: checking for each product line or model variant which category the battery belongs to, rather than making this a blanket decision for the entire range. After all, an assortment of e-bikes and scooters can easily contain batteries of different capacities and applications.

Check who in the chain is responsible for the passport

A battery is often built into a larger product — a bike, a scooter, a machine. This does not change the question of whether a passport is needed, but it does change the question of who prepares and guarantees that passport. The battery is built into my product — who then makes the passport addresses that allocation of roles. For an importer who imports complete vehicles with a built-in battery, this means that it must be checked within the own chain which party supplies which data and who bears which responsibility: the cell manufacturer, the battery assembler, or the party placing the final product on the EU market.

Take into account your own deadline

Not all battery categories are introduced to the passport at the same time. When does the battery passport become mandatory describes the relevant date for each category. For a company, this means that its own planning should be reviewed per product category, rather than assuming one fixed date for the entire range.

Make a distinction between battery types that do not fall under this obligation

Not every battery a company handles falls under the passport. Portable batteries — think of loose batteries for consumer electronics — have their own regime, which differs from that of EV, LMT and industrial batteries. Do portable batteries also need a battery passport goes further into this. Also, a car starting battery does not automatically fall into the same category as an EV battery; does a car starting battery fall under the battery passport describes that distinction. For a trading company with a mixed range, this means that each product line must be assessed separately, rather than treating the entire range with the same brush.

Where things go wrong in practice

A few situations come up regularly in practice.

An importer of e-bikes assumes that the battery of the bicycle automatically falls under the same rules as the battery of an electric car, because both "feel EV-like". This is not automatically correct: the battery of an e-bike is usually classified as an LMT battery, a category with its own characteristics. Does an e-bike or scooter battery require a battery passport describes that distinction.

A machinery manufacturer assesses the battery of one machine type, concludes that it remains below the 2 kWh threshold, and assumes that this also applies to the rest of the range — while a next model with a larger battery does exceed that threshold.

A company that both imports vehicles with built-in batteries and sells separate replacement batteries treats both streams as the same product, whereas the responsibility for the passport may differ per stream.

An importer of home batteries for residential properties assumes that this segment falls outside all legislation because it does not involve vehicles, while stationary storage has its own position within the regulation. Does the battery passport apply to a home battery or stationary storage addresses that position.

A company that has been working with the old Battery Directive for some time assumes that the new regulation covers roughly the same matters, and thereby misses that there are substantial differences in what is now expected. What is the difference between the Battery Regulation and the old Battery Directive sets that difference side by side.

What you can record

For a company that wants to maintain an overview, it is practical to document a number of matters in writing per product line:

An overview of all battery types in the range, with per type the category (EV, LMT, industrial above 2 kWh, portable, or other) and the justification for that classification.
For industrial batteries: the established capacity in kWh per model, with the source of that establishment (manufacturer specification, measurement, technical file).
Per product line: which party in the chain compiles the passport and which data are received from whom for that purpose.
A timeline per category with the relevant moments when obligations come into force, aligned with your own range.
Correspondence with manufacturers or suppliers regarding the data needed for the passport, so that in the event of a later enquiry it is clear who supplied what.

Whoever has once drawn up this overview per product line can use it as a basis for the question that stood at the beginning of this article: not in general terms, but per model and per battery type. What is a battery passport exactly is a good starting point for those who still need to make this classification and first want to understand what content goes into that passport.

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.