EU Battery Passport responsibilities for importers of e-bikes, e-scooters and electric vehicles

Yes — in most cases, an e-bike traction battery is an LMT battery and, from 18 February 2027, must have an EU Battery Passport when placed on the EU market or put into service. An LMT battery is sealed, weighs no more than 25 kg and powers a wheeled vehicle. The 2 kWh threshold does not apply to LMT batteries.

If the scooter contains an LMT battery, from 18 February 2027 each such battery placed on the EU market or put into service must have a Battery Passport. The economic operator placing the battery on the market is responsible for ensuring that its data are accurate, complete and up to date. A manufacturer may act on its behalf, but this does not automatically transfer responsibility.

Usually yes, although the exact category depends on factors including battery weight and vehicle classification. A traction battery for a category L vehicle weighing up to 25 kg may be an LMT battery; above 25 kg it may be an electric vehicle battery. Both categories are covered from 18 February 2027.

It depends on the battery parameters and the vehicle’s legal classification. Check the type-approval category, battery purpose, weight and capacity, and whether it is an LMT, electric vehicle or industrial battery. The commercial term “cabin scooter” does not determine the classification.

Usually yes. A sealed battery weighing no more than 25 kg and designed to power a cargo bike will normally be an LMT battery. Private or commercial use does not by itself change the battery category.

The specific battery and vehicle design must be assessed. A battery meeting the LMT definition is covered regardless of capacity. If classified as an industrial battery instead, the passport requirement applies when its capacity exceeds 2 kWh.

Not always. The threshold above 2 kWh applies only to industrial batteries. Every LMT battery and every electric vehicle battery is covered without a minimum capacity threshold.

Yes, if it meets the LMT definition and is placed on the market or put into service from 18 February 2027. This applies both to a battery installed in a new vehicle and to a replacement battery sold separately.

Yes. The Regulation also covers batteries incorporated into or installed in vehicles and other products. Importing a complete e-bike, e-scooter or moped does not exclude its battery from the requirements.

Yes, if it belongs to a covered category. The obligation depends on the battery category, purpose and date of placing on the market or putting into service, not on how it is installed.

The economic operator placing the battery on the EU market is responsible for ensuring that the information is accurate, complete and up to date. A non-EU manufacturer may provide data and operate the passport technically, but the importer should clearly allocate responsibility for the identifier, QR code, updates and continuity of access.

It may prepare the data or operate the passport under written authorisation. This does not release the operator placing the battery on the EU market from responsibility for the data. The importer should retain access to source data, documentation and the update process.

Potentially yes. An importer or distributor placing a battery on the market under its own name or trademark is treated as the manufacturer. The same may apply after a modification affecting compliance or a change in the battery’s intended purpose.

The importer should exercise due care and must not place a battery on the market when it knows or has reason to believe that it is non-compliant. In practice, this means checking completeness, the applicable model and plant, formats, units, sources and the link between individual data and the serial number.

Yes. Data collection, mapping and validation, passport generation, identifiers and QR codes may be handled by an external partner. The company placing the battery on the market should nevertheless retain control over data, permissions, documentation and continuity of access.

If the battery is covered by Article 77 and is placed on the market or put into service from 18 February 2027 without a passport, it will not comply with that requirement. A market-surveillance authority may require corrective action, restrict or prohibit availability, withdraw it from the market or order a recall.

No, if its battery is covered by Article 77 and is first placed on the market or put into service from that date. A missing battery passport can affect whether the complete product may lawfully be placed on the market.

The Regulation connects the obligation with placing the battery on the market or putting it into service, rather than prescribing one automatic check at every customs clearance. The safest operating model is to complete the data, identifier, QR code and passport before commercial placement on the EU market.

The decisive point is when the individual battery was first placed on the EU market. Physical presence in a warehouse does not always settle this question. Companies should retain evidence of the date and nature of the transaction and assess transitional stock against their distribution model.

Yes. The passport contains information shared at model level and information specific to the individual battery. Every covered battery must have its own electronic record linked to a unique identifier.

Not as one shared record for all units. Model-level data may be reused, but every battery requires its own passport and unique identifier.

The Battery Passport must be accessible through a QR code linked to the battery’s unique identifier. The process must unambiguously connect the physical battery, serial number, QR code and correct electronic record.

The scope is set out in Annex XIII. It includes battery and manufacturer identification, place and date of manufacture, category, weight and chemistry, technical and durability data, carbon footprint, recycled content, and information for dismantling, repair and recycling. Access to some data is restricted by user role.

Data may come from battery, cell and module manufacturers, material suppliers, the assembly plant, vehicle manufacturer, conformity documentation, tests, calculations and the battery management system. Each field should be assigned to a data owner and an evidence source.

The passport should accompany the battery through its lifecycle, while its data remain accurate, complete and up to date. Reuse, repurposing or remanufacturing may require a new record linked to the original. The passport ceases to exist after the battery has been recycled.

First identify the missing information, its owner and any alternative reliable source. Then assign follow-up actions, validate the information and document unresolved gaps before placing the battery on the market.

Provide the manufacturer with a structured list of fields, formats, units and documents. Start with manufacturer and plant identification, model and serial numbers, category, weight, capacity, chemistry, technical parameters, conformity documentation and the source for each field.

Before ordering products that will be placed on the market from 18 February 2027. The most time-consuming work is allocating responsibility, collecting and checking supplier data, resolving gaps, agreeing identifiers and QR codes, and updating supplier contracts.