Does my battery need a passport? Run the scope test.

From 18 February 2027, Article 77 of the EU Batteries Regulation (Regulation (EU) 2023/1542) requires a battery passport — but only for three categories of battery. Everything else is out, whatever its size or chemistry. The test is short, but the edge cases catch people: an e-bike battery is in scope at any capacity, a laptop battery never is, and a battery you never thought about because it ships inside a finished product is still yours to worry about. Work through the questions below.

In one line: a battery needs a passport from 18 February 2027 if it is an EV battery, an LMT battery (e-bikes, e-scooters, e-mopeds — no capacity threshold), or an industrial battery above 2 kWh — including when it arrives inside a finished product, in which case the duty falls on the importer of that product.

Question 1: is it one of the three in-scope categories?

The passport obligation covers exactly three battery types:

EV batteries — all of them, in electric cars, vans, trucks, e-motorcycles and micro-cars.
LMT batteries (light means of transport) — e-bikes, e-scooters, e-mopeds. There is no capacity threshold: a small 250 Wh e-bike pack is in scope just as much as a large one.
Industrial batteries above 2 kWh — forklifts, AGVs, machinery, telecom backup, stationary energy storage. Here the 2 kWh line matters: at or below it, no passport.

If your battery is none of these, stop — no passport is required, though other parts of the Batteries Regulation (labelling, collection, due diligence) may still apply.

Question 2: does "inside a product" get you off the hook?

No — this is the most expensive misconception in the market. Article 1 of the regulation applies to batteries incorporated into or added to products. If you import e-bikes, electric machinery or vehicles into the EU, you are placing the battery inside them on the EU market, and the passport duty lands on you as the importer of the finished product. You can delegate the data-gathering to your factory; you cannot delegate the accountability.

Question 3: is it explicitly out of scope?

Portable consumer batteries do not need a passport. That covers the batteries in laptops, phones, tablets, cordless power tools, toys and household devices. They face labelling and collection rules under the same regulation — but not Article 77. If your product line is consumer electronics or power tools, the battery passport is not your problem; do not let a checklist written for EV suppliers convince you otherwise.

The edge cases, decided

Small e-bike battery (say 300 Wh)? In scope. LMT has no capacity threshold — the category, not the size, decides.
Home energy storage unit, 5 kWh? In scope. Stationary storage counts as industrial, and 5 kWh is above the 2 kWh line.
Golf trolley or mobility scooter battery? In scope as LMT — these are light means of transport, whatever the marketing category says.
Cordless drill, even a big one? Out. Portable consumer battery — labelling rules yes, passport no.
Forklift traction battery? In scope: industrial and well above 2 kWh.

Still unsure where a product sits? PassPer's free readiness check gives you a verdict per product, and the battery passport checklist tells you what to prepare if the answer is "in scope".

Frequently asked questions

Our e-bike batteries are small — under 500 Wh. Surely they are exempt?

No. The LMT category has no capacity threshold. Every e-bike, e-scooter and e-moped battery placed on the EU market from 18 February 2027 needs a passport, regardless of size. The 2 kWh threshold applies only to industrial batteries.

Do laptop and power-tool batteries need a battery passport?

No. Portable consumer batteries — laptops, phones, tablets, cordless power tools — are outside the passport obligation. They are still covered by other parts of the Batteries Regulation, such as labelling and collection requirements, but Article 77 does not apply to them.

Is a home battery storage system in scope?

Yes, if it is above 2 kWh — which virtually all home storage systems are. Stationary energy storage is treated as industrial, so a typical 5 or 10 kWh wall unit needs a passport from 18 February 2027.

The battery arrives inside a finished product we import. Who is responsible?

You are. The regulation explicitly applies to batteries incorporated into products, and the economic operator placing the product — and the battery inside it — on the EU market is the importer. The passport must exist, be accurate and stay current, and that responsibility cannot be contracted away.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

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