Battery passport for electric bikes and scooters
Batteries for e-bikes and electric scooters fall under the LMT regime — the most demanding of the three, with 54 mandatory data points on 18 February 2027, and no capacity threshold whatsoever. A 0.5 kWh battery is in scope exactly as a 1.5 kWh one is.
LMT battery — 54 of 71 data points mandatory
on 18 February 2027
Article 3 defines an LMT battery as a sealed battery of 25 kg or less designed to provide traction to a wheeled vehicle that can be powered by an electric motor alone or combined with human power. Almost every e-bike and scooter battery meets that definition. It is the heaviest of the three regimes: the Commission guidance lists 54 mandatory data points for LMT batteries, against 51 for electric vehicle batteries and 36 for industrial batteries.
Applicable threshold. No capacity threshold: unlike industrial batteries, no minimum rating exempts an LMT battery. The only way out is weight — above 25 kg, the battery moves into a different regime.
Source: Regulation (EU) 2023/1542 and the European Commission guidance document "Digital Batteries Passport – data points by category", version 2.0 of 15 August 2026, which lists 71 data points and their applicability by battery category.
What is in scope, and what is not
Subject to the passport
- Electric bicycle batteries, whether removable or integrated into the frame
- Electric scooter batteries, including shared free-floating fleets
- Cargo bike and delivery bike batteries
- Replacement and aftermarket batteries placed on the market after 18 February 2027
Out of scope
- Batteries powering accessories on non-assisted bicycles (lights, GPS): portable batteries, outside Article 77
- Batteries above 25 kg, which fall under the electric vehicle battery regime
What you actually have to produce on 18 February 2027
Not every data point in the passport is due when it opens. The Commission guidance distinguishes, for each battery category, what is mandatory at the deadline from what is still waiting for its legal framework. Scoping the project against the full list means over-investing; ignoring the distinction means rebuilding in two years.
Mandatory at the deadline
- ✓Unique battery identifier and economic operator identifier, reachable through a data carrier affixed to the battery
- ✓Model, manufacturer, date of placing on the market and place of manufacture
- ✓Chemical composition, critical raw materials and hazardous substances
- ✓Rated capacity, voltage, power and expected cycle life
- ✓State of health and usage history, restricted to legitimate interested parties
- ✓Disassembly, safe removal and end-of-life handling instructions
Not yet due — and why
- ○Carbon footprint declaration: the delegated act setting the calculation methodology has still not been adopted, and for LMT batteries the declaration only applies from 18 August 2028 in any case
- ○Carbon footprint performance class and maximum threshold: later still, and dependent on the same delegated act
- ○Recycled content declaration: 18 August 2033 for LMT batteries, six years after the passport opens
Also worth tracking: supply chain due diligence obligations (Article 48), postponed to 18 August 2027 by Regulation (EU) 2025/1561, with an exemption for companies with a turnover below EUR 40 million.
Where the data comes from in this sector
The hard part of a Battery Pass project is almost never the passport itself: it is knowing who holds each piece of data, how often it changes, and who is entitled to read it. Article 77 and Annex XIII impose tiered access — not every mandatory data point is public.
| Data | Who holds it | Frequency | Access |
|---|---|---|---|
| Unique identifier and pack reference | Pack assembler — often a third party (Bosch, Shimano, Yamaha) rather than the bicycle manufacturer | At creation | Public |
| Chemical composition and critical raw materials | Cell maker, through the pack assembler | At creation | Interested parties |
| Capacity, voltage, warranted cycles | Assembler test data | At creation | Public |
| State of health and cycles completed | Pack BMS, read in the workshop or through the brand's app | Continuous | Interested parties |
| Repairs and pack replacement | Store network and authorised workshops | Per intervention | Interested parties |
| Collection scheme and end-of-life instructions | Producer responsibility scheme and manufacturer | At creation | Public |
How state of health gets in when the battery is not connected
State of health is the only passport data that has to stay alive after the battery is placed on the market. The market talks about connecting to the BMS as if it were a given — it is not: most batteries in service report nothing continuously. Three routes coexist, and on this segment it is field agent that is the realistic default.
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.
Limited to connected e-bikes and shared fleets, whose packs report their cycle count continuously.
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.
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.
Periodic extraction from the dealer network's service tool: one batch of readings updates the passports of every pack that came through the workshop.
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.
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.
The general case. The salesperson or repairer scans the pack in store, reads state of health from the diagnostic tool and writes it to the passport — including for a pack bought elsewhere.
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 and are not mutually exclusive: a mixed estate usually combines a BMS feed on recent equipment, a batch import for the installed base, and a field reading for anything that comes through the workshop. Every write is timestamped and attributed to its source, which is what makes the history hold up under inspection.
The three hard parts specific to this sector
The battery is not made by the bike brand
In most cases the pack comes from a third-party supplier, and the cell maker sits one step further back. The economic operator responsible for the passport has to obtain data it does not produce itself — composition, chemistry, recycled content — and be able to evidence where it came from.
The passport follows the battery, not the bike
An e-bike battery is replaced two or three times over the life of the bike, and a pack can move from one bike to another. The passport is attached to the battery: you must be able to detach it from the finished product, attach it to a new carrier, and keep the history.
High volume, thin margin
An e-bike manufacturer places tens of thousands of batteries on the market every year. Passport creation has to be industrialised from the ERP or PLM, with no manual entry and no prohibitive unit cost.
What the passport gives you beyond compliance
A battery passport reduced to an obligation stays a cost. The same data, properly structured, serves operations and the residual value of the fleet.
Safety and targeted recall
Fires involving light mobility batteries have put the sector under scrutiny. A unique identifier per battery makes it possible to target a recall at a specific cell batch rather than a whole range, and to track which units were actually returned.
Making reuse pay
A documented state of health makes a second-hand pack sellable. It also enables controlled refurbishment, by separating recoverable packs from those that go straight to recycling.
Shared fleets
Free-floating operators manage thousands of interchangeable batteries. The passport becomes the fleet register: where the pack is, how many cycles it has done, when it is due for replacement.
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 — E-bikes & scooters
Is my electric bike battery covered by the battery passport?+
Yes, in almost every case. An electric bicycle battery is an LMT battery within the meaning of Article 3 of Regulation (EU) 2023/1542: sealed, 25 kg or less, designed to provide traction to a wheeled vehicle powered by an electric motor combined with human power. The passport becomes mandatory for any LMT battery placed on the Union market from 18 February 2027, with no capacity threshold.
Is there a 2 kWh threshold for bicycle batteries?+
No. The 2 kWh threshold applies to industrial batteries only. An LMT battery is covered whatever its capacity: a 500 Wh e-bike battery is subject to the passport exactly as a 1,500 Wh one is. This is the most common misunderstanding on this segment.
How many data points does a bicycle battery need?+
The European Commission guidance of 15 August 2026 lists 71 data points for the battery passport. For LMT batteries, 54 of them are mandatory on 18 February 2027 — the highest count of the three categories, ahead of electric vehicle batteries (51) and industrial batteries (36).
Who creates the passport when the battery comes from a supplier?+
The obligation falls on the economic operator that places the battery on the Union market under its own name or trade mark, or that imports it. A bicycle manufacturer selling a third-party pack remains responsible for that pack's passport when it places it on the market inside its own product. That calls for contractual commitments from the supplier on data provision and accuracy.
What happens when a customer replaces the battery?+
The replacement battery is a distinct battery, with its own identifier and its own passport, as soon as it is placed on the market after 18 February 2027. The replaced battery's passport continues to exist until it is recycled: Article 77 provides that the passport ceases to exist once the battery is recycled.