What is a light means of transport battery (LMT battery)?
LMT battery: for light means of transport such as e-bikes and scooters, up to 25 kg
An LMT battery (battery for light means of transport) is a battery designed exclusively to power wheeled vehicles that are used by a rider or that carry goods, with a maximum of four wheels, and that do not require type-approval as a vehicle. This concerns batteries installed in electric bicycles, electric cargo bicycles, e-scooters and similar light means of transport. An additional characteristic from the definition is the weight: the battery itself weighs less than 25 kg. This category is one of five battery groups distinguished by the Battery Regulation, alongside, among others, portable batteries, batteries for electric vehicles (EV batteries) and industrial batteries.
What is and what is not included in this category
The LMT category is intended for vehicles that do not fall under the type-approval rules for motor vehicles. An electric bicycle with pedal assistance and a light electric scooter are the clearest examples: they do not require a registration plate or type-approval, and the battery that provides the propulsion falls under LMT. A speed-pedelec, moped or scooter that does require type-approval as an L-category vehicle falls outside this definition — the battery for that vehicle then falls under the EV battery category, even though the vehicle appears similar in size to a light two-wheeler. The weight of the battery is the second distinction: a pack of 25 kg or heavier no longer falls within the LMT definition, even if the vehicle otherwise meets all other characteristics. A spare battery sold separately for the same type of e-bike falls under the same category as the battery originally built into the vehicle.
From when the digital product passport for this category is mandatory
For LMT batteries, the obligation to provide a digital product passport applies from 18 February 2027, the same as for EV batteries and industrial batteries above 2 kWh. Until that date, there is no legal obligation to provide a passport, although other obligations under the Battery Regulation — such as labelling and due diligence requirements — remain applicable on their own dates. A fixed date for any transitional arrangements for batteries already placed on the market before 18 February 2027 cannot be found in the sources used here; anyone seeking certainty on this point should consult the full text of the Regulation.
What this means for those placing e-bikes, scooters or similar vehicles on the market
For an importer or distributor of light electric vehicles, the first step is to determine whether the vehicle falls within the LMT definition: no type-approval requirement as a vehicle, and a battery under 25 kg. If that is the case, then the battery is an LMT battery and the requirements established for this category apply to it, including the digital product passport from now on. The second step is to determine who in the supply chain is responsible for compiling the data that must be included in that passport — often this is the battery manufacturer or the party placing the vehicle on the European market under its own name. The third step is to inventory the source data: cell chemistry, capacity, origin of raw materials, and data on repair and recycling are components that appear in such a passport. Those who begin this work in good time will prevent the compilation of the passport from becoming an obstacle shortly before the date when the obligation takes effect.
The definition in the Regulation: Article 3
This description comes directly from Article 3 of Regulation (EU) 2023/1542 (Battery Regulation), which sets out the definitions of the different battery categories. Article 1 of the same regulation describes the subject matter and scope, and confirms that the regulation applies to all categories of batteries distinguished in Article 3, with LMT batteries as one of the five main categories. For the full, legally precise text of the definition — including the exact wording regarding wheeled vehicles and type approval — the regulation itself is the appropriate source.
Those wishing to verify whether a specific vehicle or battery type falls within the LMT category can compare the definition in Article 3 with their own product specifications: the number of wheels, whether type approval as a vehicle is required, and the weight of the battery are the three benchmarks. Batpas.eu monitors developments regarding the mandatory requirement of 18 February 2027 and assists in compiling and hosting the digital product passport once the battery or vehicle data are known.
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
Correctly identify the battery as an LMT battery
An LMT battery is, according to Article 3 of the Battery Regulation, a battery specifically intended for wheeled or one-, two- or three-wheeled vehicles: think of e-bikes, electric scooters and scooters, and similar light electric vehicles. For an importer or assembler of such products, the first practical step is to establish that the battery indeed falls into this category and not into another. This distinction is not always trivial: a battery pack that in terms of power and format looks suspiciously similar to an LMT battery can, in a slightly different application area, still be classified as something else. Anyone in doubt as to whether a particular vehicle and its associated battery fall under this category will find a more detailed explanation on which batteries fall under the Battery Regulation. For a company with 10 to 100 employees, this means in particular: when purchasing and classifying products, record on the basis of which characteristics a battery has been designated as LMT, so that this choice can be reconstructed later.
Determining who bears the obligations
The regulation imposes obligations on the manufacturer, and in practice often on the party placing the product on the EU market — in the case of imported e-bikes and scooters, this is usually the importer. Article 1 describes the scope of the regulation in broad terms, which means that a company sourcing batteries from a third country and selling them under its own name or brand will in practice face obligations similar to those of a manufacturer. This is relevant for administration: determining who within the company fulfils the role of "responsible party" for the LMT battery is a question that can be answered early in the process, not only during an inspection. A more detailed explanation of this allocation is available on the battery is built into my product — who then creates the passport?, which is relevant once the battery is not sold separately but is part of the vehicle.
Distinguishing from other battery categories
LMT batteries are distinguished in the regulation from portable batteries, industrial batteries and electric vehicle batteries (EV batteries). This distinction is not merely cosmetic: each category has its own regime within the regulation, with its own obligations and timelines. A battery pack that initially appears to be a portable battery — for example due to its weight or application — may nevertheless qualify as an LMT battery through its use in a vehicle. For companies that trade in both portable and LMT batteries, this distinction is something to document per product line; a comparison with portable batteries is available on do portable batteries also need a battery passport?.
Taking into account the upcoming obligation
The obligation to maintain a digital product passport for LMT batteries applies from a date specified in the regulation. For a company that imports e-bikes or scooters, this means that preparation time is already relevant now: the passport requires data that are collected from the design and procurement of the battery onwards, not something that can be quickly assembled afterwards. More on the exact date and what precedes it is available on when does the battery passport become mandatory?.
Understanding what the passport contains
Apart from the question of whether a battery falls under the obligation, it is useful to know what the passport actually is: a digital file with data on the composition, origin, performance and repairability of the battery, made accessible via a QR code on the product. For those who do not yet have a clear understanding of this, an explanation is available on what is a battery passport exactly?.
Where things go wrong in practice
A common situation is that an importer of e-bikes assumes that the supplier in Asia is responsible for battery classification and the passport, while in practice responsibility lies with the party that introduces the product into the EU. A second situation: a company sells both complete e-bikes and separate replacement batteries, and treats both as the same product, while the obligations may differ per sales format. A third situation arises with scooter manufacturers who assemble a battery pack themselves from purchased cells — this creates uncertainty about who exactly is the manufacturer of the LMT battery: the cell supplier, the pack assembler, or the vehicle manufacturer. A fourth, often underestimated situation is the confusion between an LMT battery and a battery for light electric commercial vehicles that is earlier classified as an industrial battery, resulting in the wrong regime being applied. A fifth situation: companies that think the date of the obligation is still far away, while data collection for the passport goes back to the design and procurement process of the battery, meaning that waiting until shortly before the deadline leaves little room for corrections.
What you can record
- An overview per product line of which batteries have been classified as LMT batteries, with the justification for that choice.
- The designation within the company of who fulfils the role of manufacturer, importer or authorised representative for each relevant battery.
- Correspondence with suppliers regarding the origin, composition and technical specifications of the battery cell and pack.
- A file per battery type with the data required for the passport: chemical composition, capacity, repairability, and origin of raw materials.
- An internal explanation of the distinction between battery categories handled by the company, so that battery classification is not lost in case of staff changes.
- A timeline towards the obligation date, including the points at which supplier data must be received in order to assemble the passport on time.
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.