Every e-bike battery needs a passport by February 2027 — whatever its size.

E-bike batteries are LMT (light means of transport) batteries under Regulation (EU) 2023/1542, and from 18 February 2027 every single one placed on the EU market must carry a battery passport — there is no capacity threshold. The rule follows the battery into the finished bike: whether you manufacture, assemble from imported packs, or import complete e-bikes, the passport for the battery inside is your problem to solve. Here is what that means in practice.

In one line: from 18 February 2027 every e-bike battery — no minimum size — needs a compliant battery passport, and if you place the bike on the EU market, making sure that passport exists, is accurate and stays current is your legal responsibility.

Why every e-bike is caught — no capacity threshold

Regulation (EU) 2023/1542 (the Batteries Regulation) gives LMT batteries — the batteries in e-bikes, e-scooters and e-mopeds — their own category, and Article 77 requires a battery passport for every LMT battery placed on the EU market from 18 February 2027. Unlike industrial batteries, there is no 2 kWh floor: a 250 Wh commuter battery is in scope just like a 1 kWh cargo-bike pack.

The regulation also applies explicitly to batteries incorporated into products. The passport duty travels with the complete bike: an e-bike imported from Asia, or assembled in the EU around an imported battery pack, needs a compliant passport for the battery inside it before it can lawfully be sold.

Supplier's battery, your responsibility

Most e-bike brands do not make their own batteries — a drive-system or battery supplier does. That splits the picture:

Battery placed on the EU market separately (a supplier sells you packs already on the EU market) — the supplier carries the passport duty for those packs, but you should verify the passport exists before the battery goes into your bikes.
Complete bikes imported with the battery inside — you, the importer, are the economic operator placing the battery on the market. The passport obligation lands on you.
EU assembly from non-EU packs — the operator bringing the packs into the EU carries the duty; if that is you, so is the passport.

In every arrangement, the brand selling the bike should be able to show, per unit, that a compliant passport exists. "Our supplier said they would handle it" is not a defence.

What an e-bike battery passport contains

A battery passport is a structured digital record of roughly 110+ data points, including:

Identity — unique identifier, model, manufacturer, manufacturing date and place.
Chemistry and materials — composition, critical raw materials, recycled content.
Carbon footprint — the battery's lifecycle emissions.
Due diligence — supply-chain responsibility information.
Performance and durability — capacity, expected lifetime, cycle data.
Circularity — dismantling, spare parts and end-of-life information.

It is carried by a GS1 Digital Link QR code on the battery and must remain accessible for the battery's regulated lifetime. The DIN DKE SPEC 99100 guidance standard describes how to structure the content.

The clock for the 2027 season

Bikes sold in spring 2027 leave factories in 2026. If your order book for the 2027 season is already open, battery-passport readiness belongs in this year's supplier negotiations — data requirements in purchase contracts, spec sheets and test reports collected up front, not chased after the container ships. PassPer turns the documents your suppliers already have — spec sheets, certificates, declarations — into registered, eIDAS-sealed battery passports using AI extraction with human review, from €79/month with a free 30-day pilot. Run the free readiness check to see where your bikes stand today.

Frequently asked questions

Our e-bike batteries are only 250–500 Wh. Surely they are too small to need a passport?

No. The battery passport obligation for LMT batteries has no capacity threshold — that is the key difference from industrial batteries, where a 2 kWh floor applies. A compact city-bike battery is in scope exactly like a large cargo-bike pack, from 18 February 2027.

Our drive-system supplier says they will handle the battery passport. Are we covered?

Partly. A major supplier will hold most of the data and may issue passports for batteries it places on the EU market itself. But if you import complete bikes with the battery inside, or place bikes on the market under your brand, you are the responsible economic operator — you must verify that a compliant, accurate passport exists for every unit. You can delegate the work in writing, not the accountability.

Do spare and replacement e-bike batteries need passports too?

Yes. The obligation attaches to every LMT battery placed on the EU market from 18 February 2027, whether it arrives inside a bike or as a spare pack in a box. Aftermarket and replacement batteries need their own compliant passports.

What happens if our bikes arrive in the EU without compliant battery passports?

From 18 February 2027 a battery without a compliant passport cannot lawfully be placed on the market — so the bike it sits in cannot be sold. Customs can detain shipments, market-surveillance authorities can order withdrawal, and member states set the fines. A season's stock stuck in a warehouse usually costs far more than any penalty.

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.

Free readiness check → See it in action Get the guide (PDF)