Battery passport for e-bike batteries and LMT batteries

Anyone in this segment who believes they are not affected usually has the same number in mind: 2 kWh. That threshold applies to industrial batteries only. For batteries of light means of transport it does not apply.

The German version of the regulation calls them LV-Batterien, while the English text calls the same batteries LMT. What is meant are batteries for pedelecs, e-bikes, e-scooters, e-mopeds and comparable vehicles. A 500 Wh pedelec battery is far below 2 kWh and still requires a passport from 18 February 2027.

That the two terms are constantly mixed up in German-language articles adds to the widespread misjudgement.

Who carries the obligation is the first question here

In this market, two companies typically sit on the same battery: the drive or system manufacturer, and the bicycle manufacturer selling the complete pedelec.

The obligation lies with the economic operator placing the battery on the EU market. Depending on the arrangement, that can fall differently:

Where the battery is sold separately as a replacement or second battery, the party placing it on the market is responsible. Where it ships as part of a complete bike, the allocation is not obvious in every case and depends on the contractual arrangement and on the brand carried by the product.

Settle this in writing with your contractual partner, and do so before the deadline pressure arrives. In this segment an unresolved allocation of responsibility is the most likely path to nobody having a passport in February 2027.

The model year change makes this a permanent topic

Unlike in many industrial segments, the portfolio here turns over annually. New model years, new battery variants, changing system partners.

The battery passport is therefore not a project with a completion date but a process that has to accompany every model change. Anyone planning implementation as a one-off exercise is building the same work again for 2028.

Practical consequence for the choice of solution: creating a new battery variant has to be something your product management can do, without a service provider touching a data model.

Serialisation down to the battery

The passport is issued per individual battery. Many manufacturers in this market serialise cleanly at vehicle level, but at the battery the chain frequently stops, especially where the battery is bought in.

Check early whether your numbering systems reach that far and whether the battery's serial number is linked in your systems to the vehicle shipped. This is preparatory work that has nothing to do with software but can take a long time.

One aspect that goes beyond compliance

The aftermarket is large in this segment, and batteries are frequently counterfeited or rebuilt improperly. A verifiable passport affixed to the product makes it visible whether a battery actually came out of your production.

For dealers, workshops and end customers that is a tangible safety argument, and for you a side effect of an obligation you have to meet anyway.

Timeline

Now to October 2026: Settle responsibility with the system partner or bicycle manufacturer in writing, list the affected battery variants, send enquiries on cell origin and CO₂ data.

October to December 2026: Set up the data model for the variants, verification in the EU DPP registry, establish serialisation down to the battery.

January 2027: Test operation, data carrier on the battery housing, alignment with retail and workshops.

Note that model year planning for 2027 is already under way in many companies. The decision on the data carrier on the housing should feed into that planning rather than come after it.

Frequently asked questions

Our battery is only 500 Wh. Are we affected anyway? Yes. There is no capacity threshold for LMT batteries.

We build bicycles, not batteries. Does this concern us? Possibly. What matters is who places the battery on the EU market. Settle this contractually with your system supplier.

Does this apply to replacement batteries as well? Yes, from the cut-off date for all newly placed LMT batteries.

What about batteries already in the market? For batteries placed on the market before 18 February 2027, no retroactive passport obligation arises.