Which batteries need a passport in 2027

From 18 February 2027, three kinds of battery need a passport before they can be placed on the EU market (Art. 77(1)):

Category	Examples	Capacity threshold
EV batteries	Traction batteries for cars, vans and other electric vehicles	None
LMT batteries	E-bikes, pedelecs, e-scooters, light e-motorcycles, mobility scooters	None
Industrial batteries above 2 kWh	Energy storage, UPS units, forklifts, telecom backup	Above 2 kWh only

The 2 kWh threshold is the most common point of confusion. It applies only to industrial batteries. An LMT or EV battery needs a passport whatever its capacity.

Portable batteries (phones, laptops, power tools) and SLI starter batteries are outside the passport duty. They don't escape the regulation, though: from the same date every battery needs a QR code, which for these batteries links to labelling information, the declaration of conformity and end-of-life information instead of a full passport.

How LMT batteries are defined

Light means of transport batteries are the category most often misjudged. Under Art. 3(1)(11), a battery is an LMT battery only if all four of these are true:

• it is sealed;
• it weighs 25 kg or less;
• it is designed to power wheeled vehicles by an electric motor alone, or motor plus human power;
• it is not an EV battery.

Intended use decides the category, not capacity. The same cells could make an LMT battery in an e-bike and a portable battery in another device. Batteries for pedelecs, e-scooters, S-pedelecs, light e-motorcycles with a sealed battery of 25 kg or less, electric wheelchairs and registered e-cargo bikes all fall in.

LMT batteries also carry duties beyond the passport: the battery and its cells must be removable and replaceable by independent professionals for the product's whole life (Art. 11), and spare batteries must stay available for at least five years after the last unit of a model is sold.

What triggers the duty

The passport follows the moment a battery is first made available on the EU market, or first put into service there:

• Sold before 18 February 2027: no passport, even if resold later.
• Made earlier, first sold after the deadline: needs a passport.
• Replacement batteries first sold after the deadline need a passport if they fall in a covered category.
• Assembling a battery from cells or modules makes you the party placing it on the market. Fitting a finished battery into a device or vehicle doesn't.
• Repurposed or remanufactured batteries need a new passport, linked to the original, from whoever puts them back on the market (Art. 77(7)).

Every battery needs its own passport, unique identifier and QR code. Passports can't be created after the fact for batteries sold before the deadline, and a model-level record isn't enough.

A quick scope check

For each product line, write down the battery type, its capacity, how it is sold (on its own, or inside a product) and when units will first reach the EU market. That table tells you which lines need a full passport, which need only a QR code, and who in your supply chain is placing each battery on the market.

FAQ

Does the 2 kWh threshold apply to e-bike batteries?

No. The 2 kWh threshold applies only to industrial batteries. LMT batteries, such as e-bike and e-scooter batteries, need a passport whatever their capacity.

Do portable batteries need a battery passport?

No. Portable and starter batteries don't need a passport, but from 18 February 2027 they still need a QR code linking to the information the regulation requires for them.

Does a battery made in 2026 need a passport if it is sold in 2027?

Yes, if it falls in a covered category. The duty follows the date the battery is first placed on the EU market, not when it was made.

Sources

• When is a battery passport mandatory?, DPP Hero
• Battery passport for e-bikes, e-scooters and LMT, DPP Hero
• Regulation (EU) 2023/1542, EUR-Lex