From 18 February 2027, every LMT battery placed on the EU market or put into service must have an electronic battery passport linked to a unique identifier via a QR code. For e-bike brands, this is not simply a matter of “putting a webpage online”; it means connecting cell, BMS, manufacturing, compliance, service and recycling data into one traceable chain.
1. Why Work Must Start in 2026: Do Not Confuse These Two Dates
|
Date |
Regulatory Requirement |
Implications for E-bike Projects |
|
2027-02-18 |
Create an electronic battery passport for every LMT battery; mark every battery with a QR code |
Serial number, unique identifier, data platform, access rights and labels must be integrated and tested before mass production |
|
2027-08-18 |
Battery supply-chain due-diligence obligations begin to apply (postponed by two years under Regulation (EU) 2025/1561) |
Raw-material sourcing, risk policies, third-party verification and reporting become a separate compliance workflow |
|
2028-12-31 |
51% collection target for waste LMT batteries |
Brands/EPR organisations need to integrate sales, take-back and destination data into operating systems |
|
2031-12-31 |
61% collection target for waste LMT batteries |
Collection networks and data quality become long-term channel capabilities, not just compliance costs |
| Scope: This article focuses on LMT batteries under Regulation (EU) 2023/1542. Complete e-bikes must still be assessed against EN 15194, market-surveillance requirements in the target Member State, transport rules, WEEE/EPR, product-safety requirements and other applicable obligations. |
2. Why an E-bike Battery Also Qualifies as an “LMT Battery”
EU rules classify a sealed battery that provides traction power to a light means of transport, can be powered by the electric motor alone or by a combination of motor and human power, and weighs no more than 25 kg as an LMT battery. E-bikes, electric mopeds and e-scooters are typical applications. The battery-passport requirement is not limited to batteries above 2 kWh; the “>2 kWh” threshold applies to industrial batteries, while LMT batteries are listed separately.
|
Common Misreading |
Correct Project Interpretation |
|
“My e-bike battery is only 500 Wh, below 2 kWh, so it does not need a passport.” |
Incorrect. LMT batteries are a separate category and are not exempted by the >2 kWh threshold for industrial batteries. |
|
“The complete e-bike has CE marking, so battery data does not need separate management.” |
Incorrect. Battery-passport responsibility rests with the economic operator that places the battery on the market or puts it into service, and the data must be accurate, complete and up to date. |
|
“Generating a static QR code completes the job.” |
Incorrect. The QR code must link to a unique identifier, and the passport must contain model-level data, restricted data and battery-specific data that changes during use. |
3. Battery Passport Data Structure: 19 + 4 + 1 + 4
Annex XIII separates information by access rights and data object. The “19 + 4 + 1 + 4” structure below is the most practical workload breakdown for building a project data repository; it does not mean 28 simple fields, as some items contain multiple sub-fields, files and dynamic records.
|
Access Level |
Regulatory Item Count |
Typical Content |
Recommended Data Owner |
|
Publicly Available Model-Level Information |
19 categories (a–s) |
Material composition, carbon footprint, responsible sourcing, recycled content, Ah, voltage, power, cycle life, temperature, warranty, efficiency, internal resistance, C-rate, declaration of conformity and end-of-life management | Regulatory / Battery R&D / Sustainability |
|
Model-Level Information for Persons with a Legitimate Interest |
4 categories (a–d) |
Detailed positive/negative electrode and electrolyte composition, part numbers and spare-part sources, disassembly diagrams and sequence, tools/fasteners/warnings/cell layout, and safety measures | R&D / After-Sales / Supply Chain |
|
Regulatory Authorities Only |
1 category |
Test-report results demonstrating compliance with this Regulation and applicable delegated acts | Regulatory / Quality |
|
Battery-Specific Data for Persons with a Legitimate Interest |
4 categories (a–d) |
Initial and status-change parameters, SOH, original/repurposed/re-used/remanufactured/waste status, cycle count/incidents/temperature/SOC | BMS / Cloud Platform / After-Sales |
- · Public fields are not marketing copy: rated capacity must be stated in Ah; power must be expressed in W with temperature limits; and expected lifetime must be stated in cycles together with the reference test method.
- · Battery-specific dynamic fields require system-level answers first: who generates the data, how often it is updated, who may read it, how data is backfilled after an offline period, and how history is inherited after a BMS replacement.
- · Passport data should be based on open standards, use interoperable, machine-readable, structured and searchable formats, and avoid vendor lock-in.
4. This Is Not a QR-Code Project: The End-to-End Data Flow
|
Supplier Data |
Manufacturing Data |
Passport Service |
Market / After-Sales Updates |
End of Life |
|
Cell Lot |
Pack SN |
Unique Identifier QR Mapping Access Control Version Log |
Cycles / SOH Incidents / Temperature Service / Replacement Status Changes |
Recycling / Re-use Remanufacturing Passport Transfer Old/New Linkage |
Supplier → incoming material/lot → battery-pack serial number → end-of-line test → QR code/unique identifier → vehicle binding → use and service events → recycling or remanufacturing
| Key responsibility: The Regulation requires the economic operator that places the battery on the market or puts it into service to ensure that the information is accurate, complete and up to date. A service provider may be authorised in writing to perform operations, but responsibility cannot simply be shifted to a QR-code platform. |
5. 90-Day ODM Project Gates: Build a Verifiable Data Prototype First
|
Gate |
Timing |
Issues That Must Be Closed |
Measurable Exit Criteria |
|
G0 Scope Freeze |
D1–D10 |
Model, SKU, EU economic operator, data ownership and platform boundary | 100% of SKUs mapped to battery models; no blank items in the RACI |
|
G1 Data Dictionary |
D11–D25 |
Annex XIII fields, units, sources, access rights and update frequency | All 19/4/1/4 categories mapped; zero missing mandatory fields |
|
G2 Identification & Labelling |
D26–D40 |
Serial number, unique identifier, QR layout, durability, duplicate/missing codes | 10,000 simulated IDs with zero duplicates; scan success rate ≥99.5% |
|
G3 System Integration |
D41–D60 |
MES/BMS/ERP/passport interfaces, access rights, versioning and resume-after-interruption capability | End-to-end record completeness ≥99.5% across 200 virtual batteries; zero unauthorised reads |
|
G4 Physical Pilot |
D61–D75 |
Bind, release, service, update status and replace parts on 50 batteries | 50/50 traceable; 100% consistency across 20 sampled data items |
|
G5 Release Readiness |
D76–D90 |
SOPs, alerts, backups, supplier contracts and audit evidence | Zero open P0/P1 issues; ≥95% of P2 issues closed; recovery drill ≤4 hours |
The figures above are PXID project-management recommendations, not mandatory test-sample sizes or system SLAs under Regulation (EU) 2023/1542. Formal thresholds should be jointly approved by the brand, economic operator, regulatory lead and system provider.
6. Battery Hardware Must Close in Parallel: Five-Year Spare Parts and Replaceability
From 18 February 2027, LMT batteries incorporated into products, as well as individual battery cells within battery packs, must be removable and replaceable by independent professionals during the product lifetime; a compatible replacement must not impair product function, performance or safety. The Regulation also requires LMT batteries to remain available as spare parts for at least five years after the last unit of the relevant equipment model is placed on the market, and software must not prevent the replacement of compatible batteries or key components.
|
Design Area |
Must Be Frozen Before DVT |
Verification Evidence |
|
Mechanical Interface |
Mounting datum, locking, water resistance, connector float, service clearance and special tools |
Removal/installation steps, tool list, repeated removal/installation and misassembly prevention |
|
Electrical / BMS |
Authentication boundary, compatible voltage/current/temperature, fail-safe behaviour and data inheritance after part replacement |
Compatibility matrix, fault injection, software versions and regression testing |
|
Spare Parts & After-Sales |
Five-year supply responsibility, part-number substitution, pricing principles, service providers and safety training |
After-sales BOM, EOL plan, inventory/substitution approval and service instructions |
|
Passport Lifecycle |
Original, re-use, remanufactured and waste status, plus linkage to a new passport |
Status-transition use cases, access records and change logs |
7. Mass-Production Gate: Six Numbers Determine Release Readiness
|
Metric |
PXID Recommended Threshold |
Purpose |
|
Unique-Identifier Duplication Rate |
0 / 100,000 |
Prevent one passport from mapping to multiple batteries or overwriting records |
|
Production-Record Completeness |
≥99.9% |
Ensure traceability of lot, SN, factory, date and initial test |
|
Random Scan Success Rate |
≥99.5%，n≥200 |
Verify label, printing, URL and mobile access |
|
Field Consistency |
20 key fields × 30 batteries, 100% consistent |
Compare MES/ERP/BMS data against the passport |
|
Access-Control Negative Testing |
≥30 test cases; zero unauthorised access |
Verify segregation among public, regulatory and legitimate-interest access |
|
Open P0/P1 Issues |
0 |
Avoid regulatory, data-security or batch-traceability failures |
| Mass-production gate: Release only when label samples, the data dictionary, interface reports, access-control tests, the 50-battery physical pilot, SOPs and responsibility sign-offs are all complete. A QR code that “opens when scanned” does not equal battery-passport compliance. |
8. External Standards and Official Links
- · Regulation (EU) 2023/1542 consolidated text (battery passport, Articles 11/13/77/78, Annex XIII)
- · Regulation (EU) 2025/1561 (due diligence postponed to 2027-08-18)
- · European Commission 2025 guidance (LMT battery removability, replaceability and five-year spare-parts availability)
- · EUR-Lex official summary (51%/61% collection targets for waste LMT batteries)
- · UNECE UN Manual of Tests and Criteria Rev.8 + 2025 Amendment（UN 38.3）
- · ISO/IEC 15459 series overview (reference standards for unique identification and QR codes)
- · ISO 4210 bicycle safety standards catalogue
FAQ
Yes. LMT batteries are separately included within the passport scope; the 2 kWh threshold applies only to industrial batteries specified by the Regulation.
No. UN 38.3 is a lithium-battery transport testing framework, while the battery passport covers material, performance, compliance, service, status and lifecycle data. The evidence should be linked, but one cannot replace the other.
The Regulation requires the label and QR code to be visibly, legibly and indelibly printed or engraved on the battery. Where this is not possible because of the battery’s nature or size, the applicable information may be placed on the packaging and accompanying documents; the specific case should be confirmed by the regulatory lead.
The Regulation requires the responsible party to keep the passport accurate, complete and up to date. Whether updates are made by the BMS, app, cloud platform or after-sales system should be defined in the project RACI and written authorisations.
Not by default. The decision must be based on battery identity, status changes and re-use/remanufacturing rules, with links between the old and new passports and a retained change history.
No. The passport requirement applies from 2027-02-18; Regulation (EU) 2025/1561 postpones the due-diligence obligations until 2027-08-18.
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