The battery passport, industry by industry
A bicycle, a tram and a rack of UPS cabinets do not fall under the same regime — and the gap is eighteen data points. Before scoping a Battery Pass project, you need to know which category your product falls into. These eight pages answer that question, sector by sector.
Three categories, three regimes
Article 77 of Regulation (EU) 2023/1542 recognises only three categories of battery subject to the passport. The European Commission guidance document "Digital Batteries Passport – data points by category", version 2.0 of 15 August 2026 lists 71 data points and indicates, for each of them, whether it is mandatory on 18 February 2027 depending on the category.
| Category | Definition (Art. 3) | Threshold | Mandatory points |
|---|---|---|---|
| LMT battery | A sealed battery of 25 kg or less, designed to provide traction to a wheeled vehicle, including type-approved category L vehicles. | No capacity threshold | 54/ 71 |
| Electric vehicle battery | A traction battery above 25 kg for a category L vehicle, or the traction battery of a category M, N or O vehicle. | No capacity threshold | 51/ 71 |
| Industrial battery | Any other rechargeable battery for industrial use — including, under recital 15, traction in rail, waterborne and air transport, and energy storage, domestic storage included. | Passport required above 2 kWh | 36/ 71 |
Portable batteries and starting, lighting and ignition (SLI) batteries remain outside the scope of Article 77: they keep their labelling and collection obligations, without a passport.
Your industry
For each segment: the classification and its legal basis, what is genuinely due on 18 February 2027, who holds the data in that sector, and how state of health gets in when the battery is not connected.
E-bikes & scooters
LMT battery
The most demanding of the three regimes, and with no capacity threshold: a 500 Wh battery is in scope.
Trams & rail
Industrial battery
Neither an electric vehicle nor exempt equipment: recital 15 places rail traction in the industrial category.
Passenger EVs
Electric vehicle battery
State of health is mandatory but restricted to interested parties: the permission model is the real subject.
Buses & trucks
Electric vehicle battery
Same regime as passenger cars, but packs that move between vehicles as availability dictates.
Energy storage
Industrial battery
From a multi-MWh container to a home battery, one and the same category. What remains is choosing the granularity.
Material handling
Industrial battery
Long-term rental, the shift from lead to lithium, and batteries that travel between sites.
Data centres & UPS
Industrial battery
The segment that does not know it is in scope: above 2 kWh, a UPS battery is an industrial battery.
Motorcycles & mopeds
LMT or electric vehicle battery
Classification turns on 25 kg — and the swappable pack changes vehicle constantly.
Three ways to keep state of health current
State of health is the only passport data that has to keep living after the battery is placed on the market. Connecting to the BMS is usually presented as the obvious answer: it only is for a minority of fleets. A tram in the depot, a rented forklift, a rack of UPS cabinets tested twice a year have no real-time feed — and still have to keep their passport current.
BMS connection
The BMS reports state of health continuously, through vehicle telematics or site supervision. The finest-grained option, but it assumes connected equipment and a data flow that already exists.
With Arianee — Event-based write API: each reading updates the passport of the battery concerned, with no re-issuance, timestamped and attributed to its source.
Batch import
Readings are extracted periodically from an existing system — supervision, fleet management, connected chargers, ERP — and loaded in batches. The realistic route when the data exists but is not exposed in real time.
With Arianee — Bulk import from the Management Hub or by API: one file or feed updates thousands of passports in a single operation, with a per-line error report.
Field agent
The technician scans the battery's QR code and enters or confirms the reading on the spot — in the workshop, in store, in the plant room. The only route when the battery is not connected, and the most reliable evidence that an intervention took place.
With Arianee — Passport Portal: the scan opens the battery's passport with the technician's rights, and they write their reading and their intervention. Works for a network of third-party workshops without opening the rest of the fleet to them.
The three routes feed the same passport, under the same permission model: every write is timestamped and attributed to its source. That is what lets you open writing to a maintainer or a network of third-party workshops without giving them access to the rest of the fleet.
François Pujo
Industrial & Battery Project Manager
François is our Battery Pass expert, working alongside industrial players worldwide to integrate DPP into their production lines and across the entire life of the product.
Frequently asked questions about the battery passport
How many battery passport categories are there?+
Three, and only three. Article 77 of Regulation (EU) 2023/1542 makes the passport mandatory for LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh. Portable batteries and starting, lighting and ignition (SLI) batteries are excluded. The category determines the number of mandatory data points and the timetable for the related obligations: it is the very first question to settle in a project.
How many data points are mandatory on 18 February 2027?+
The European Commission guidance document "Digital Batteries Passport – data points by category", version 2.0 of 15 August 2026, lists 71 data points and sets out their applicability by category. On 18 February 2027 the mandatory counts are: 54 data points for LMT batteries, 51 for electric vehicle batteries and 36 for industrial batteries. The balance corresponds to obligations whose legal framework is not yet complete, chiefly carbon footprint and responsible sourcing.
Is a tram battery an electric vehicle battery?+
No. The definition of an electric vehicle battery covers road vehicles of categories L, M, N and O. Recital 15 of the Regulation states that batteries intended for traction in rail, waterborne and air transport are industrial batteries. The same applies to material handling equipment, to stationary storage batteries — domestic storage included — and to UPS batteries.
Does the 2 kWh threshold apply to every battery?+
No, only to industrial batteries. LMT batteries and electric vehicle batteries are subject to the passport with no capacity threshold. A 500 Wh electric bicycle battery is therefore covered, while a 1.5 kWh industrial battery is not.
Who has to create the battery passport?+
The economic operator that places the battery on the Union market — the manufacturer, the importer, or the distributor selling it under its own name or trade mark. Operators, rental companies and maintainers do not create the passport, but they hold part of the data that has to be maintained over the life of the battery, in particular state of health and intervention history.
Is all passport data public?+
No. Article 77 and Annex XIII organise tiered access between the general public, legitimate interested parties — repairers, refurbishers, end-of-life operators — and market surveillance authorities and notified bodies. State of health, for example, is mandatory data but is not public.