The short answer
Whether a battery falls under the digital product passport depends first and foremost on the battery type and, for industrial batteries, on the capacity. The battery regulation targets the product passport at three categories: batteries for electric vehicles, batteries for light means of transport such as e-bikes and scooters, and industrial batteries above 2 kWh. Other batteries, such as individual consumer batteries you sell as a by-product, generally fall outside this specific product passport requirement, although other obligations under the regulation may apply to them.
Whether your company is affected thus does not depend on the question of whether you "work with batteries" in some way, but on what exactly is in your assortment and how large the capacity is. An installation company that only sells small backup batteries below 2 kWh is in a different position than a company that supplies industrial battery packs of 5 kWh to machinery manufacturers.
Which batteries the regulation names
The regulation distinguishes batteries by use, not by brand or price. EV batteries are installed in passenger cars, vans and comparable vehicles. LMT batteries are installed in light means of transport: e-bikes, electric scooters, cargo bikes with pedal assistance. Industrial batteries are installed in machines, storage systems and comparable applications, and only become subject to the product passport requirement above a capacity threshold of 2 kWh. What exactly falls under this and how that threshold is measured is best read directly in the official text, as the definitions are more precise than a short summary can convey.
If you are uncertain which category your product falls into, that is in itself no cause for concern: many companies in the sector face the same question, especially in borderline cases such as a battery pack that can be used both in a light scooter and in a stationary application. In the knowledge base with topics per situation the breakdown by battery type is elaborated further.
Why the 2 kWh threshold is often the core of the question
For EV and LMT batteries, the question "does this fall under the regulation" is usually answered quickly: if it is a battery for a vehicle or light means of transport, it is in principle at issue. For industrial batteries it is more nuanced, because capacity is decisive. A small backup battery for an alarm system falls below the threshold; a battery pack for a forklift or a storage system can be well above it.
This means in practice that two companies with a comparable assortment may still be affected differently, simply because their products fall just on either side of that threshold. For a machinery manufacturer that supplies both small and large battery packs, this may mean that part of the assortment requires a product passport and another part does not.
What this means for your company also depends on your role
Whether you are affected by the product passport depends not only on the battery type, but also on your position in the chain: are you the manufacturer, importer or distributor of the battery, or only of the device in which the battery is installed. This question is separate from this page, but is at least as important to answer before you draw conclusions about your own situation.
It is therefore not surprising if the initial impression is that the rules "are about batteries, but not clear about yours". This is precisely where a targeted check is useful, instead of reading through the entire regulation looking for your own situation.
How to verify this for your own assortment
A good first step is to establish for each product line: is this an EV battery, LMT battery or industrial battery, and what is the capacity in kWh. Based on that, it becomes clear which part of your assortment may fall under the passport obligation, and which part does not. For cases of doubt, it is advisable to consult the definitions in the official text or involve a lawyer, especially if the outcome has consequences for your purchasing or sales contracts.
With the product scan that provides an indication in a few questions you quickly get an initial picture of where your products presumably stand, without having to work through the entire regulation immediately. This is an indication, not a legal assessment of your specific situation.
Doubt is part of this phase
It is normal that companies at this moment still have questions about where their assortment precisely stands: the obligation only applies from 18 February 2027, and many companies are still working through this kind of fact-finding work. Those who now already map out which product lines do and do not fall under the passport, will not have to do that later under time pressure.
Do you want to know where your own assortment presumably stands? Take the free quick scan or read the other topics in the frequently asked questions about the battery passport to further explore your situation.