The E-Bike Importer's Guide to the Battery Passport

If you import e-bikes or e-bike batteries into the EU, the battery passport is your obligation and the date is 18 February 2027. This guide pulls the whole picture together for the e-bike trade specifically: what applies, what does not apply yet, what to collect, and what to do between now and the deadline.

First, confirm the obligation is yours

The regulation puts the passport duty on the economic operator that places the battery on the EU market. An importer is defined as a person established in the EU who places on the market a battery from a third country (Art. 3 of Regulation (EU) 2023/1542). If you buy complete e-bikes or battery packs from a manufacturer in Asia and sell them in the EU under your own name, that is you.

It does not transfer. Your supplier's CE mark, test reports and datasheets are inputs to your passport, not a substitute for it, and the duty does not move to a marketplace or a freight forwarder. See who is responsible for the battery passport.

Separately from the passport, importers carry a set of checks before placing a battery on the market: verifying the manufacturer prepared the EU declaration of conformity and the technical documentation, that the battery carries the CE marking and the required labelling, and adding your own name and postal address to the battery (Art. 41). You must keep the declaration of conformity for ten years.

What is in scope for an e-bike business

Every e-bike battery is an LMT battery, and LMT batteries need a passport at any capacity. There is no threshold to fall under, so a 400 Wh commuter pack and a 1,000 Wh cargo pack are treated alike. See battery passport requirements for LMT batteries.

Three product situations all count:

• Complete e-bikes with the battery included. The battery is the covered product even inside a finished vehicle.
• Spare and replacement packs sold on their own, which each need their own passport.
• Batteries you supply under warranty or service, if that supply is the first time that battery is made available in the EU.

The trigger is placing on the market, not manufacture or shipping, so stock that lands before the deadline and stock supplied after it can be treated differently. See when a battery counts as placed on the EU market.

What bites when

This is where e-bike importers lose the most time, because the regulation phases obligations and not all of them arrive with the passport. For LMT batteries:

• Already in force. The separate collection symbol has applied since 18 August 2025.
• 18 February 2027. The battery passport applies, and the QR code giving access to it must be on the battery (Art. 13(6) and Art. 77). This is the wall.
• The general battery label runs on its own clock. Art. 13 sets its date as the later of 18 August 2026 or 18 months after the Commission's labelling act takes effect, so it moves with that act rather than sitting on a fixed day. Check where that act stands before you plan around a date.
• 18 August 2028 at the earliest. The carbon footprint declaration begins for LMT batteries, tied to a Commission method.
• 18 August 2033. Recycled content documentation begins for LMT batteries, with the minimum shares reaching this category later still.

The practical reading: for an e-bike importer in 2026, the carbon footprint and recycled content questions are not the near-term problem. Identity, composition, performance, safety, dismantling information, the label and the hosting are.

The data to collect

The passport carries the Annex XIII data set, organised by who may see each field. For an e-bike pack you are gathering:

• Identity and composition: model identifiers, chemistry, materials, and any substances of concern.
• Performance and durability: rated capacity, voltage range, expected lifetime in cycles with the reference test, round-trip energy efficiency, internal resistance, operating temperature range.
• Dismantling and safety: how the pack comes apart, the tools and fastenings involved, warnings, cell layout, and the safety measures. This tier exists for repairers and recyclers.
• Conformity evidence: the test reports behind the declaration of conformity.
• Waste handling and label information, which the passport pulls in alongside the rest.

Most of this originates with the manufacturer. See what your supplier must send you, and when the answer is thin, how to collect passport data from a supplier who only sends a spec sheet.

Labels and the production line

The QR code has to be printed or engraved visibly, legibly and indelibly on the battery itself, and may only go on the packaging and accompanying documents where the battery's size or nature does not allow it (Art. 13(7)). For an e-bike pack, which has plenty of surface area, plan on the battery.

That has two consequences for how you order:

1. The passport has to exist before the label is printed, because the code points at it.
2. The web address must stay stable for the life of the pack, because you cannot reprint a code on batteries already sold. See the data carrier and QR code rules.

Fold this into the factory conversation early. Marking is a tooling and artwork change at the plant, and plants schedule those in production runs, not in a week.

Hosting is the lasting commitment

The passport must stay reachable and accurate for as long as the battery is in service, ceasing only once the battery has been recycled. Responsibility sits with the operator that placed it on the market. E-bike packs commonly stay in use for years and change hands second-hand, so the record has to outlast your interest in that model. See how long a battery passport must stay online.

A working plan to February 2027

Assuming you start now, roughly:

1. Now: confirm scope per model. List every battery model you place on the market, spare packs included. Run each through the scope checker.
2. Next: one structured data request per supplier, covering the whole field list for every model, with a deadline set well before your own cut-over.
3. Autumn 2026: sort the gaps. Escalate to cell makers where needed and write the data into the terms for the next production run.
4. Winter 2026: artwork and marking. Agree QR placement and the marking method with the factory so it is in the production run, not bolted on.
5. Before February 2027: passports live and hosted, with the web addresses fixed and every model checked.
6. From 18 February 2027: keep it current as models change, and keep passports reachable for packs already sold.

In short

Every e-bike battery is in scope at any capacity, and the duty is yours as the importer placing it on the EU market. The passport and its QR code apply from 18 February 2027; the carbon footprint and recycled content obligations for LMT batteries come much later, in 2028 and 2033. Spend this autumn on the supplier data, the dismantling and safety detail, and factory marking, and treat hosting as a commitment that outlives the model.

If you want a hand with the scope check and to hear when the passport builder opens, start with the scope checker.