Battery passport for e-bike manufacturers and importers

If a battery falls into the category of light means of transport (LMT), the battery passport requirement is not limited by the 2 kWh threshold. In Article 77, that threshold applies to industrial batteries. What matters is the correct classification of the product and the situation in which the battery is placed on the market or put into service.

From when the obligation applies to LMT batteries

Article 77 of Regulation (EU) 2023/1542 requires, from 18 February 2027, a passport for each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service. This requirement is not a blanket order to retrofit passports to all old batteries already with customers.

Before preparing data, we therefore need to know which batteries you actually supply, what role your company has and who places the battery on the EU market. A retailer, an importer and a manufacturer selling under its own brand do not necessarily have identical obligations. We determine the specific responsibility based on the actual supply chain.

One set of model documentation, individual batteries

Model information does not have to be entered manually again for each battery. The common specification, revisions and documents are prepared for the model. Each individual battery is then assigned its identity and the relevant data. Replacement batteries also matter: their identity must not be lost just because you only record the e-bike frame.

Illustrative example: an importer has five models and 5,000 batteries per year. The source data may be prepared in a single spreadsheet, or split across several manufacturers. The volume is the same, but the rollout effort differs significantly depending on the quality of the inputs and the level of automation required. This is not a client reference or a price quote.

What to request from the manufacturer

• Exact model and revision designation, chemistry and parameters.
• The serial number structure and its link to the delivery.
• Product documentation and the sources of the required data.
• Information on whether a passport already exists and who manages it.
• A contact person who will confirm corrections and other changes.

Not every field applies equally to all categories and deadlines. We use a requirements matrix that matches your product. We do not replace a missing expert result, such as a measurement, with a marketing estimate.

The passport can also help after the sale

Besides the mandatory information, the stable QR link can lead to the correct manual, warranty documents, a service contact and other approved content. Some repair and dismantling information already falls within the legal framework; legally required access must not be restricted by adding a marketing gate. Professional repairers should not automatically receive all of the company's internal documents.

How to start without a big project

For the pilot, we suggest one model, a sample of unit-level data and one responsible team. We validate the assignment of documents, the import, access rights and approvals. Only then do we define the scope of further automation. If your supplier already creates a passport, we first check how it can be used and do not needlessly add a second passport for the same battery.

Comparison of implementations · Discuss our battery model

Legal basis: Regulation (EU) 2023/1542, in particular Art. 3, 77, 78 and Annex XIII. Overview checked on 11 October 2026. This text does not replace an individual legal assessment.