Battery passport for electric motorcycles and mopeds
This is the one segment where classification turns on a kilogram. A category L two-wheeler battery is an LMT battery up to 25 kg, and an electric vehicle battery above it. Two regimes, 54 or 51 mandatory data points, and a usage model — the swappable pack — that the passport has to be able to follow.
LMT up to 25 kg, electric vehicle battery above
on 18 February 2027
Article 3 of Regulation (EU) 2023/1542 defines an LMT battery as a sealed battery of 25 kg or less intended to provide traction to a wheeled vehicle, including type-approved category L vehicles. The definition of an electric vehicle battery covers traction batteries above 25 kg in category L vehicles, and batteries in categories M, N and O. For a powered two-wheeler, it is therefore the weight of the battery that decides: 25 kg or less means the LMT regime and 54 mandatory data points; above that, the electric vehicle regime and 51.
Applicable threshold. The weight of the pack, not its capacity nor the power of the vehicle. A manufacturer offering several battery configurations on one model can end up with two different regimes inside a single range.
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
- Batteries in category L electric mopeds and motorcycles
- Swappable packs in battery swap networks
- Replacement batteries placed on the market after 18 February 2027
Out of scope
- SLI batteries in combustion two-wheelers, outside Article 77
- Accessory batteries falling under the portable 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 identifier per pack, swappable packs included
- ✓Manufacturer, model, date and place of manufacture
- ✓Chemistry, critical raw materials and hazardous substances
- ✓Capacity, voltage, power and expected service life
- ✓State of health and usage history, restricted to legitimate interested parties
- ✓Disassembly instructions and end-of-life information
Not yet due — and why
- ○Carbon footprint declaration: on hold pending the delegated act on calculation methodology, with different deadlines depending on whether the battery falls under the LMT or the electric vehicle regime
- ○Responsible sourcing: due diligence postponed to 18 August 2027
- ○Recycled content declaration: 18 August 2028 for electric vehicle batteries, 18 August 2033 for LMT batteries — the gap follows the classification that applies
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 |
|---|---|---|---|
| Pack identifier and declared weight | Manufacturer or pack assembler — the weight determines which regime applies | At creation | Public |
| Chemistry and critical raw materials | Cell maker, through the assembler | At creation | Interested parties |
| Capacity, voltage, warranted cycles | Manufacturer testing | At creation | Public |
| State of health and cycles completed | Pack BMS, read on the vehicle or at the swap station | Continuous | Interested parties |
| Successive assignment to vehicles | Swap network operator | Per intervention | Interested parties |
| End of life and treatment route | Manufacturer and producer responsibility scheme | 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 bms connection 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.
On connected vehicles, the pack reports its cycles exactly as in automotive.
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.
In a swap network, the station reads each pack's condition at every exchange: readings come back in batches, station by station.
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.
In after-sales and at the dealership, for unconnected packs and for single-pack replacements.
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
Two regimes inside one range
A manufacturer offering an urban and a touring version of the same model can cross the 25 kg line on one and not the other. The data model has to carry classification per pack reference, not per vehicle model.
The swappable pack changes vehicle constantly
In a swap network, one pack passes through dozens of vehicles and stations. The passport follows the battery: it has to record a succession of assignments and holders without ever losing the thread of the usage history.
Several packs per vehicle
Configurations with two or three removable packs multiply the number of passports per vehicle sold, and require handling of unpairing and single-pack replacement.
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.
Running a swap network
The passport becomes the register of the pack fleet: state of health, cycles, home station, packs due for withdrawal. Regulatory data that serves operations directly.
Resale and the second-hand market
On a used two-wheeler, a documented pack state of health removes the buyer's main uncertainty.
Safety and targeted recall
A unique identifier per pack allows a recall to be confined to one cell batch and the units actually returned to be tracked.
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 — Motorcycles & mopeds
Is an electric moped battery an LMT battery or an electric vehicle battery?+
It depends on its weight. Article 3 of Regulation (EU) 2023/1542 defines an LMT battery as a sealed battery of 25 kg or less intended to provide traction to a wheeled vehicle, including type-approved category L vehicles. Above 25 kg, a traction battery in a category L vehicle falls under the definition of an electric vehicle battery. For a moped or an electric motorcycle, the weight of the pack therefore determines the regime.
What difference does that make in practice?+
The number of data points mandatory on 18 February 2027 — 54 of 71 under the LMT regime, 51 of 71 under the electric vehicle regime — and the timetable for the related obligations. The recycled content declaration, for instance, is due on 18 August 2028 for electric vehicle batteries but only on 18 August 2033 for LMT batteries.
How should swappable batteries in a swap network be handled?+
Each pack is a distinct battery, with its own unique identifier and its own passport, whatever vehicle it happens to be in at a given moment. The passport has to record a succession of assignments to vehicles and stations, and keep receiving state of health data from the network operator.