For e-bikes & light means of transport
Battery passports for e-bikes and light means of transport
High volumes, thin margins and a supply chain that holds most of the data you need to declare. The passport work here is mostly about getting data out of suppliers in time.
Updated 2026-09-20 · All industries · Guides to the regulation
Why LMT is the hardest volume case
LMT batteries are in scope in exactly the same way as EV and large industrial batteries, but the commercial reality is different: more units, lower value per unit, and a supply chain where the brand on the bike often did not build the pack. The compliance data — cell chemistry, composition with CAS numbers, carbon footprint, recycled content — sits with a supplier who has never been asked for it in this form.
This is why the work should start long before the deadline. Software takes an afternoon. Getting a complete substance table out of a cell manufacturer takes months.
The supplier problem, concretely
For a typical LMT pack you need, among other things:
- chemistry and a substance list with CAS and EC numbers and mass percentages;
- carbon footprint per kWh, with the basis of the calculation;
- post-consumer recycled shares of cobalt, lithium, nickel and lead — zero is a valid answer, but it must be declared;
- rated capacity and energy, nominal voltage, cycle life and the conditions it was measured under;
- safe-removal and dismantling information for repairers and recyclers.
Two practical tips. Put these deliverables in your purchase terms now, with a deadline earlier than February 2027. And ask for values, not for a PDF datasheet: a passport needs structured fields, and re-typing them from documents is where errors are introduced.
OrigoPass has a supplier request for this: you select the fields you are missing, the supplier gets a personal link, fills in only those fields, and nothing they submit is used until you accept it. Every acceptance is sealed in the register, so you can show where a declared value came from.
Labels that survive a bike
An LMT pack lives outdoors, gets charged in a shed, is carried by hand, and may be serviced by a shop that never met your brand. The data carrier has to keep working through all of that, and the URL it carries cannot change — not when you change supplier, and not when you change platform. A code printed on a label that points at a supplier domain is a risk you carry for fifteen years, which is why passports on your own domain matter more here than anywhere else.
What repair shops and recyclers will actually use
LMT batteries are repaired, refurbished and dismantled far more often than EV packs, usually by independent shops. The restricted part of the passport is what makes that safe: cell configuration, safe-removal steps, the substances inside. Under Article 77 those parties can ask for access; you decide and the grant is recorded. In practice a well-filled restricted tier reduces your support load, because the shop stops calling you for the same information.
Volume without drudgery
- Declare each pack model once, then register units by Excel upload or API — serial number and date per unit.
- Pre-create identifiers so labels can be produced ahead of assembly.
- Keep model data versioned: a corrected carbon footprint creates a new version, and passports already sealed keep the version they were made with.
- Plan for the assortment, not just the flagship: most brands discover they have more battery variants than product lines.
General information, not legal advice. Verify obligations for your specific products against the regulation and, where needed, with a qualified adviser.
Frequently asked
Do e-bike batteries need a battery passport?
Yes. Batteries for light means of transport (LMT) — e-bikes, e-cargo bikes, e-scooters and similar vehicles — are explicitly in scope. Every LMT battery placed on the EU market from 18 February 2027 needs its own digital passport reachable through a QR code on the battery.
We buy complete battery packs from an Asian supplier. Who is responsible?
You are, as the importer placing the battery on the EU market. The supplier is not established in the EU, so the obligation lands with you: you declare the data, you answer to market surveillance, and you need the underlying information from your supplier in writing.
Does the passport go on the battery or on the bike?
On the battery. The passport identifies the battery unit, so the data carrier belongs on the pack itself and has to survive removal from the bike, storage, service and eventually recycling.