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If you sell e-bikes in the EU, the battery file is no longer something the factory keeps and you never see. From 18 February 2027, every light means of transport (LMT) battery placed on the EU market or put into service needs a digital passport. The battery in your e-bike is an LMT battery, so this applies to you.
Two things decide whether you'll be ready. First, can your battery supplier hand over product and traceability data you can trust? Second, have you written down who builds and maintains the passport? Answer both before you lock the next production order.
18 February 2027
The key date: Article 77 of Regulation (EU) 2023/1542 requires each LMT battery placed on the EU market or put into service from this date to carry a battery passport. E-bike batteries fall inside the LMT category.
A battery passport is a digital record for one battery, not a model brochure. A QR code on the battery opens a unique identifier, which pulls up the record. Part of it describes the model — chemistry, capacity, manufacturer. The rest belongs to that single battery, including its serial number and history.
The passport is not one open page for everyone. The public sees a limited set of fields. Repairers, recyclers and other authorised parties see more, under defined access rights. Authorities can request the full set. When you plan the data, you also have to decide which field goes to which audience.
The regulation gives light means of transport its own battery category. It covers batteries that power light electric vehicles, e-bikes and e-scooters among them. Every LMT battery placed on the EU market or put into service from 18 February 2027 needs its own passport.
Don't confuse the passport with what you already hold. A factory datasheet or a test report contains useful source data, but neither is the passport, and a QR code that links to the bicycle's product page does not satisfy the requirement. The duty sits on the battery itself. If you import complete e-bikes, bring in replacement batteries, or sell batteries under your own brand, go through each battery model and check how individual units are identified.
The duty falls on the economic operator that places the battery on the EU market. Depending on your setup, that is the EU importer, the battery manufacturer, or another operator selling the battery under its own name. That operator answers for the accuracy of the data and keeps it current. It can authorise another operator in writing to do the work, but the legal responsibility does not move.
On an OEM or private-label order, the factory usually holds most of the technical data, while the brand or importer is the operator placing the battery on the market. They are not the same party, and the gap causes problems if no one addresses it.
Put the following in writing before production: who supplies the data, who reviews it, how the QR artwork and serial numbers are handled, who hosts the record, and who keeps it updated. Add a clause for what happens if the supplier or brand relationship ends.
The Commission's guidance groups passport data points by battery category and states which fields apply from February 2027. Not every field in the regulation is due on day one. Ask for what applies to your battery and the start date, and split the request into two blocks.
Battery model, category and manufacturer; the details that identify each individual unit; chemistry, rated capacity, voltage and weight; the substances and materials used; and the performance and durability data that apply to this category.
The serial-number structure and unique identifier, a process for linking the physical battery to its digital record, and the technical documents and test data that let the responsible operator verify what it publishes.
A filled-in questionnaire is the start, not the finish. Compare the answers against specifications, test records and the actual battery configuration. Data copied from an old catalogue is how passports end up wrong.
No. The obligations do not all start together. The Commission's FAQ states that carbon-footprint, recycled-content and due-diligence information is not required when the passport first applies in February 2027. Each has its own later date and conditions.
Demanding every future field as if it were already mandatory confuses suppliers and stalls the project. Ask for the February 2027 set now, and keep a separate list of what comes later.
List the battery models. Name every e-bike and replacement battery intended for the EU.
Identify the responsible operator. Fix which company places each battery on the market and owns the passport.
Send a structured data request. Ask for the model and traceability data the LMT fields require.
Verify the data. Check supplier answers against specifications, test records and the real battery.
Plan the identifier and QR marking. Coordinate them with the responsible operator and production.
Decide who maintains the record. Cover hosting, access, corrections and updates, including a change of supplier.
Review each model before shipment. A passport for one model does not cover a different battery.
The passport is one layer, not the whole file. It does not replace conformity assessment, technical documentation, product marking or transport documents for the finished e-bike and its battery. The complete e-bike, its electrical system and the battery are assessed separately under the product legislation and standards that apply, and lithium batteries keep their own transport requirements.
Don't leave this to the shipping stage. The obligations depend on the product configuration and the role of each operator, which only get harder to change late in the project. Build the checks into product development and supplier management.
On an OEM/ODM project, we work with you on product configuration, component selection, supplier coordination and production preparation. For the battery, we can identify the model used, collect the technical information the supplier can provide, and align the specifications and identification details before production.
The operator placing the battery on the EU market confirms the legal requirements and runs the passport process; we don't take that role. Our advice is to bring the battery supplier into the compliance discussion early. Checking what data exists during development is far simpler than chasing missing information after the order is done.
The requirement applies to LMT batteries placed on the EU market or put into service from 18 February 2027, and e-bike traction batteries fall inside that category. Confirm the classification for the specific battery with a compliance adviser.
No. The passport has to be linked to the battery through the prescribed identifier and QR system. A general QR code on a frame or product page does not meet the battery-level requirement.
The responsible operator can authorise another operator in writing to act on its behalf. Agree the scope, access to source data and ongoing maintenance. The legal responsibility stays with the operator identified under the regulation.
No. It is a separate requirement under the Batteries Regulation and does not replace conformity assessment or transport documentation that applies to the product or shipment.
No. The current Commission FAQ says that information is not required at the initial start. Check the latest guidance for the exact data points and later dates.
European Commission — Digital Product Passport for Batteries
European Commission — EU Digital Product Passport FAQ for Batteries
European Commission — Guidance to support preparations for the Digital Batteries Passport
Note: This article is for general information and is not legal advice. EU requirements and guidance may be updated. Check the latest legislation and Commission publications, and seek advice from a qualified compliance professional for your product and role in the supply chain.
Talk to Hottech about your specifications, battery options and OEM/ODM production. We can help coordinate the technical information during project preparation.
