Passports for E-bike and E-scooter (LMT) Batteries

E-bike, e-scooter and electric moped batteries form a category of their own in the EU Battery Regulation: the light means of transport (LMT) battery. From 18 February 2027 it enters the Digital Product Passport duty on the same day as EV and industrial batteries; but the pack is small, the margin thin and the supply chain mostly in Asia, so the problems differ from the EV battery.

For the general framework see what the battery passport is; this article covers what is specific to LMT.

The LMT definition and its edges

The regulation defines an LMT battery by four criteria: sealed, 25 kg or less, specifically designed to provide traction for wheeled vehicles powered by an electric motor alone or by a combination of motor and human power, and not an EV battery. Type-approved L-category vehicles, such as electric mopeds, are inside the definition.

Both edges matter. Small consumer batteries outside the definition are "portable" and outside passport scope; packs above 25 kg, or whose vehicle category changes, may shift into EV or industrial rules; see which batteries, who is obligated.

Three categories, different obligations

Where does the QR go on a small pack?

The QR must be on the battery, not the vehicle: the passport belongs to the battery, which can leave the vehicle. With the e-bike pack buried in the down tube, the e-scooter pack hidden in the deck and the casing curved, that rule becomes concrete:

1. The code must sit on a flat face visible once the battery is removed; the face pointing into the frame is useless.
2. Laser marking on the casing, or a label under lacquer, beats an adhesive label against abrasion and moisture.
3. Do not shrink the module size or quiet zone; test readability on the curved surface with several phones.
4. Carry the same identifier in vehicle documents and the after-sales system; the user often scans the vehicle.

The regulation lets the code move to packaging and documents where the battery's nature and size do not permit it; LMT packs are too large for that exception. Print-quality rules are in DPP QR codes: size, placement and print; placement alongside battery symbols and CE marking in battery labelling and QR codes; the app-free access principle in EN 18220.

The brand that buys packs in Asia

The typical LMT model: the brand designs the vehicle, buys the pack in Asia and sells the vehicle in the EU. For the regulation, the party first placing the pack on the EU market is the importer, responsible for the passport existing, being accurate and staying current. The obligation cannot be transferred to a pack maker outside the EU, yet most of the data sits there: chemistry, critical raw materials, carbon-footprint inputs, dismantling information.

The purchase contract is therefore the passport contract: a serial-number list per delivery, a data set per model, an update obligation. For the roles see economic operators and their responsibilities. For pack makers in Türkiye selling into the EU, the other end of the chain is in the battery passport for Turkish battery manufacturers.

Replaceability and rental fleets

The regulation requires LMT batteries to be removable and replaceable by an independent professional (Article 11). The dismantling and safety information in the legitimate-interest tier is the data side of that requirement; a workshop outside your network must be able to read it.

For shared e-scooter and e-bike fleets the passport is more than a burden. The fleet operator may carry responsibility as the party putting batteries into service; in return, BMS SoH data (Article 14) serves fleet rotation, warranty claims and second-hand sale. See battery state of health and dynamic data for update cadence and privacy design, and the battery passport guide for the category-wide framework.

Frequently asked questions