[{"data":1,"prerenderedAt":160},["ShallowReactive",2],{"blog-en-2-kwh-schwelle":3},{"id":4,"title":5,"author":6,"body":7,"date":145,"description":146,"extension":147,"meta":148,"metaDescription":149,"metaTitle":150,"navigation":151,"path":152,"seo":153,"slug":154,"stem":155,"tags":156,"__hash__":159},"blog_en\u002Fen\u002Fblog\u002F2-kwh-schwelle.md","The 2 kWh threshold does not apply to every battery","Lucas Johns",{"type":8,"value":9,"toc":136},"minimark",[10,14,17,22,25,32,41,47,50,54,57,60,64,67,70,73,76,80,83,86,89,93,122,130],[11,12,13],"p",{},"“Our batteries are well below 2 kWh, this does not concern us.” That sentence comes up regularly in conversations about the battery passport, and in roughly half of the cases it is wrong.",[11,15,16],{},"The 2 kWh threshold in the Battery Regulation (EU) 2023\u002F1542 is not a general de minimis limit. It applies to exactly one category.",[18,19,21],"h2",{"id":20},"what-the-threshold-applies-to","What the threshold applies to",[11,23,24],{},"From 18 February 2027, three battery categories require a passport:",[11,26,27,31],{},[28,29,30],"strong",{},"Electric vehicle batteries."," No capacity threshold.",[11,33,34,37,38],{},[28,35,36],{},"LMT batteries",", meaning batteries for light means of transport. ",[28,39,40],{},"No capacity threshold.",[11,42,43,46],{},[28,44,45],{},"Industrial batteries above 2 kWh."," Here, and only here, the limit applies.",[11,48,49],{},"Portable batteries and starter batteries do not require a passport.",[18,51,53],{"id":52},"the-confusion-around-the-term","The confusion around the term",[11,55,56],{},"Part of the misunderstanding is self-inflicted. The German version of the regulation says LV-Batterien, while the English text calls the same batteries LMT, for light means of transport. Many German-language articles use both terms side by side without resolving them, and some list LV batteries in tables in a way that carries the 2 kWh figure down from the row above.",[11,58,59],{},"What is meant are batteries for pedelecs, e-bikes, e-scooters, e-mopeds and comparable vehicles. A 500 Wh pedelec battery therefore requires a passport, even though it reaches a quarter of the threshold that applies to industrial batteries.",[18,61,63],{"id":62},"the-other-direction-those-who-count-themselves-too-small","The other direction: those who count themselves too small",[11,65,66],{},"The opposite mistake is at least as widespread. Many manufacturers never classify their product as an industrial battery in the first place, because the word sounds like a factory floor.",[11,68,69],{},"The regulation, however, knows no separate category for stationary storage. A home storage system is an industrial battery. A 5 kWh entry-level system is above the threshold, a 10 kWh system all the more so. In this segment the limit excludes practically no product on the market.",[11,71,72],{},"The same applies to traction batteries. A 48 V battery with 500 Ah comes to around 24 kWh, twelve times the threshold. Even small batteries for low-lift pallet trucks are above it. And because the regulation distinguishes by category and capacity rather than by cell chemistry, a PzS lead-acid battery is affected just as much as a lithium system.",[11,74,75],{},"Further cases that fall under industrial batteries and are frequently overlooked: UPS systems, batteries in cleaning machines and automated guided vehicles, marine propulsion, emergency power systems.",[18,77,79],{"id":78},"why-the-classification-matters-now","Why the classification matters now",[11,81,82],{},"Anyone who wrongly assumes they are not affected loses the lead time, which is genuinely short. The demanding part of introducing a battery passport is not the software but obtaining data from upstream suppliers. Carbon footprint of the cells, recycled content shares, material composition: this sits outside your own company, often across several tiers and frequently in Asia.",[11,84,85],{},"Experience shows that a supplier enquiry across two tiers takes months. Anyone who finds out in January 2027 that they are affected after all will no longer make the date.",[11,87,88],{},"The check itself costs half an hour: which category, what capacity, and do we place the finished product on the EU market ourselves?",[18,90,92],{"id":91},"for-your-segment","For your segment",[94,95,96,104,110,116],"ul",{},[97,98,99],"li",{},[100,101,103],"a",{"href":102},"\u002Fen\u002Fbattery-passport\u002Fhome-storage","Home storage systems",[97,105,106],{},[100,107,109],{"href":108},"\u002Fen\u002Fbattery-passport\u002Fforklift-batteries","Forklift and traction batteries",[97,111,112],{},[100,113,115],{"href":114},"\u002Fen\u002Fbattery-passport\u002Fe-bike-battery","E-bike batteries and LMT batteries",[97,117,118],{},[100,119,121],{"href":120},"\u002Fen\u002Fbattery-passport\u002Fimporters","Importers",[11,123,124,125,129],{},"The basics on who needs a passport, the data points under Annex XIII and the three access levels are summarised on our ",[100,126,128],{"href":127},"\u002Fen\u002Fbattery-passport","battery passport overview page",".",[11,131,132],{},[133,134,135],"em",{},"Last updated: August 2026. Editorial guidance, not legal advice. Only the respective legal act in its applicable version is binding.",{"title":137,"searchDepth":138,"depth":138,"links":139},"",2,[140,141,142,143,144],{"id":20,"depth":138,"text":21},{"id":52,"depth":138,"text":53},{"id":62,"depth":138,"text":63},{"id":78,"depth":138,"text":79},{"id":91,"depth":138,"text":92},"2026-08-18","Which batteries the 2 kWh limit of the Battery Regulation actually covers, and why many manufacturers of e-bike batteries and home storage systems classify themselves wrongly.","md",{},"The Battery Regulation's 2 kWh limit explained: which batteries it really covers and why many manufacturers classify themselves wrongly.","The 2 kWh threshold does not cover every battery",true,"\u002Fen\u002Fblog\u002F2-kwh-schwelle",{"title":5,"description":146},"2-kwh-schwelle","en\u002Fblog\u002F2-kwh-schwelle",[157,158],"Battery passport","Battery Regulation","8Zn2i_1zQh0ZY6d39uzse9eNlTVdhfjqP6oKPrZs1sQ",1787840219171]