what is meant by an industrial battery in the regulation

What you need to do concretely

What is expected of you

The Battery Regulation works with fixed categories, and "industrial battery" is one of them. Article 3 of Regulation (EU) 2023/1542 (Battery Regulation) contains the definition: an industrial battery is a battery designed for industrial use, and which does not fall under the other categories — so not under portable batteries, not under LMT batteries (light means of transport), not under EV batteries and not under vehicle starter batteries. In practice it is a residual category: anything made for business or industrial use and that does not fit anywhere else falls under this heading.

This makes the category broad. A battery pack in a production machine, the energy storage behind a charging station, an emergency power supply in a server room, a battery pack in a robotic arm or a high-power wheelchair — these are all examples that in practice are classified as industrial. For companies that build machines, installations or equipment with a built-in battery, this is often the category their product falls into, even if "industrial" at first glance suggests a heavier load than the device in question carries.

Determining whether the battery is actually industrial

For a business with 10 to 100 employees that purchases, processes or resells batteries, the first step is to determine which category a battery falls into precisely. This is not done on a whim, but on the basis of the definitions in Article 3. In practical terms, this means that per product line or per purchased battery type, you look: is this a battery for a light means of transport, is it in a vehicle, is it designed as portable for consumers, or is it simply for something else — and then there is a good chance that "industrial" is the correct classification. If you have doubts about this, you can use the question which batteries fall under the battery regulation? as a starting point to set the categories side by side.

Taking the 2 kWh threshold into account in the assessment

Industrial batteries are subject to the passport obligation only from a certain capacity onwards. This is a crucial point: a small industrial battery pack of a few hundred watt-hours is treated differently from a large pack of tens of kilowatt-hours. For companies, this means that the capacity of each battery type in their own product line must be clearly mapped — not as a loose technical specification, but as something that directly determines whether the passport procedure applies. More on where exactly that threshold lies and what it means can be found at what does the 2 kWh threshold mean for industrial batteries?

Determining who is responsible for the passport

Article 77 of Regulation (EU) 2023/1542 (batteries regulation), article 77 stipulates that a digital battery passport must be drawn up for batteries that fall under the passport obligation. For industrial batteries placed on the market independently, that responsibility usually lies with the manufacturer or the importer who places the battery on the EU market. For batteries that are built into a machine or installation, the question of who is responsible is less straightforward — it depends on who places the assembled product on the market. Machinery manufacturers who source batteries and incorporate them into their own equipment would be well advised to clarify this beforehand, and the page the battery is built into my product — who then creates the passport? goes into this further.

Making distinctions with related categories

Because industrial batteries are a residual category, most confusion arises at the edges: where does "industrial" end and something else begin. A battery in an electric cargo bike, for example, can come close to the definition of an LMT battery, and a stationary storage system at a company can be regarded as either industrial or as something else, depending on the application. For companies that have these kinds of borderline cases in their range, it is advisable to document per product group why a particular category was chosen, and not simply to rely on what the supplier calls the product.

Where things go wrong in practice

A first recurring situation: a company uncritically adopts the designation of the supplier or manufacturer without checking it against the definition in Article 3. If the supplier calls it "industrial" when it is actually a portable battery, or vice versa, an incorrect assessment of the obligations arises.

A second situation: the capacity of the battery pack is not recorded or is not checked when there are changes in the design. A pack that initially fell below the 2 kWh threshold can, in a subsequent product version, exceed it, without this being noticed in the administration.

A third: companies that build machines or installations with a built-in battery assume that the battery supplier is responsible for the passport, whereas that responsibility actually lies with the person placing the assembled end product on the market.

A fourth situation arises in companies that have both industrial and other battery types in their range — for example an importer of both e-bike batteries and stationary storage systems. Without a clear classification per product line, the passport procedure for one type is accidentally applied to the other, or omitted entirely.

A fifth: in case of doubt about the category, the matter is shelved for too long, while clarity about the category is the basis for everything that follows — from the content of the passport to the question of who must supply it.

What you can record

• An overview per product line or battery type, with the chosen category (industrial, LMT, portable, EV or starting battery) and the substantiation for it on the basis of Article 3.
• The established capacity (in kWh) of each industrial battery pack, including when it was established and who established it.
• Correspondence or specifications from the manufacturer or supplier in which the technical characteristics of the battery are described.
• An established agreement on who in the chain is responsible for providing passport data, especially for batteries built into your own equipment.
• A control point for product modifications, so that a change in the battery pack is re-assessed against the classification and the capacity threshold.

For those who, after this classification, still wish to verify whether the obligation is already applicable in time, when does the battery passport become mandatory? provides further clarity on this.