If you manufacture both electric vehicle batteries and light means of transport batteries, you cannot use a single passport template for both. The EV vs LMT battery passport distinction is written into Regulation (EU) 2023/1542, and the two battery types carry different data requirements, different parametric ranges, and different compliance burdens. This article explains what those differences are, where they come from in the regulation, and what they mean for your operations before the 18 February 2027 deadline.
What the Regulation Actually Says About Scope
Article 77 of Regulation (EU) 2023/1542 requires a battery passport for every EV battery and every LMT battery placed on the EU market. Both categories share the same compliance date: 18 February 2027. There is no phased timeline between them.
The definitions matter here, and they are not about capacity. Article 3(11) defines an LMT battery as one that is sealed, weighs 25 kg or less, and is designed to provide electric power for the traction of wheeled vehicles: e-bikes, e-scooters and similar light electric vehicles. Article 3(14) defines an electric vehicle battery by the vehicle it powers and, in one limb, by the weight of the battery itself: a battery weighing more than 25 kg that provides traction in a hybrid or electric vehicle of category L, or any battery that provides traction in a hybrid or electric vehicle of category M, N or O. The 25 kg is the weight of the battery, not of the vehicle. Neither definition sets a kWh threshold. The 2 kWh figure that appears in Article 77(1) belongs to industrial batteries. The boundary matters when you are classifying your products for passport purposes.
Both battery types must comply with Annex XIII of the regulation in full. Annex XIII sets out four access tiers for passport data. Point 1 covers information available to the public. Point 2 covers information available to persons with a legitimate interest and the Commission. Point 3 covers information available to notified bodies and market surveillance authorities. Point 4 covers individual-battery data for persons with a legitimate interest. The data you must collect and disclose sits across all four tiers, and neither EV nor LMT batteries are exempt from any of them.
EV vs LMT Battery Passport: Where the Data Requirements Diverge
The European Commission’s guidance enumerates 71 data points in total across Annex XIII. Of those, 47 are mandatory for EV batteries at the February 2027 date, and 50 are mandatory for LMT batteries, per Commission guidance v2.0 of 15 August 2026. The difference of three data points reflects slightly different parametric ranges and performance thresholds that apply to each battery category under the regulation.
In the Traceable platform, those regulatory data points are decomposed into individual fields. EV batteries require 98 data fields in the Traceable template. LMT batteries require 111 data fields. The higher field count for LMT batteries reflects the additional parametric granularity needed for that category, not a broader regulatory obligation. To be clear: the 98 and 111 figures are Traceable platform attributes. The 47 and 50 figures are the Commission’s enumerated mandatory data points. These are two different counting methods and should not be mixed.
What does this mean in practice? If you are building a data collection process for an EV battery, you will gather and verify 98 discrete pieces of information in the Traceable template. For an LMT battery, that rises to 111. The additional fields in the LMT template capture things like the specific performance parameters relevant to lower-capacity, higher-cycle-count applications typical of e-bikes and e-scooters.
The Weight Boundary and Why It Creates Classification Risk
The 25 kg threshold in Article 3(11) is the boundary that manufacturers of cargo bikes, delivery vehicles and high-performance e-scooters need to watch. A sealed pack weighing 24 kg that powers an e-cargo bike is an LMT battery. The same pack at 26 kg is not, and if it provides traction in a category L vehicle it is an electric vehicle battery under Article 3(14) instead. If your product line spans that boundary, you may have batteries that look similar but require different passports.
Electric vehicle batteries are not classified by capacity at all. A 20 kWh pack in a small city car and a 100 kWh pack in a large SUV are both EV batteries under the regulation, and so is a considerably smaller pack in a car, van or truck, because for vehicles of category M, N or O Article 3(14) turns on the vehicle category rather than the energy stored. The 2 kWh threshold often quoted alongside EV batteries is not theirs: Article 77(1) applies it to industrial batteries. A small traction battery in a passenger car is still an electric vehicle battery, and it still requires a passport.
The real asymmetry is not one of capacity. LMT is bounded by weight at 25 kg; for cars, vans and trucks the electric vehicle category has no weight limit at all. It is the manufacturer whose packs grow heavier, rather than larger in kWh, who needs to re-check classification at each new product launch. Getting this wrong means filing the wrong passport type, which is a compliance failure under Article 77.
What Both Passport Types Require in Common
Despite the differences in field counts and parametric ranges, EV and LMT batteries share a substantial common core of Annex XIII entries. Both are subject to:
- A carbon footprint declaration, covering the full lifecycle of the battery, at Annex XIII point 1(c), which refers to the carbon footprint rules in Article 7(1) and (2). Under Commission guidance v2.0 this entry is not to be filled or displayed as of 18 February 2027; it applies in line with the Article 7 methodology delegated act, which has not yet been adopted.
- A recycled content disclosure, specifying the percentage of recycled cobalt, lithium, nickel, and lead used in the battery, at Annex XIII point 1(e). Under Commission guidance v2.0 these entries are not to be filled or displayed as of 18 February 2027; they apply in line with the Article 8(1) methodology delegated act, which has not yet been adopted.
- The material composition of the battery, including its chemistry, the hazardous substances it contains other than mercury, cadmium and lead, and the critical raw materials present, as required under Annex XIII point 1(b). Annex VI Part A is incorporated separately, by Annex XIII point 1(a).
- Supply chain due diligence documentation, covering the sourcing of materials identified as high-risk under Article 52.
These four obligations apply equally to both battery types. A manufacturer who has already built a carbon footprint methodology for EV batteries does not need to build a separate methodology for LMT batteries, but they do need to apply it to each LMT battery model and record the result in a separate passport.
Separate Passports Are Not Optional
If you produce both EV and LMT batteries, you must maintain separate passports for each battery type. Article 77 does not permit a combined or shared passport across categories. One template does not satisfy both obligations.
This has direct operational consequences. Your data management process needs to handle two distinct passport structures simultaneously. Your supplier data requests need to specify which battery type the data is for, because the field requirements differ. Your quality and compliance sign-off process needs to verify the right template has been used for each product line.
For manufacturers who currently manage compliance informally, perhaps through spreadsheets or document folders, the February 2027 deadline means building a structured system that can maintain both passport types without confusion. The risk of applying an EV template to an LMT battery, or vice versa, is not just an administrative error. It is a failure to comply with Article 77, which can trigger market surveillance action under Chapter X of the regulation.
Practical Steps for Manufacturers Producing Both Battery Types
The following steps reflect the requirements of Regulation (EU) 2023/1542 and are not legal advice. Consult your legal team for advice specific to your situation.
- Classify every battery model in your product range against the definitions in Article 3. Confirm whether each model is an electric vehicle battery under Article 3(14), which turns on vehicle category, or an LMT battery under Article 3(11), which requires the battery to be sealed and to weigh 25 kg or less. Flag any models near the 25 kg boundary for additional review.
- Build separate data collection templates for each battery type. Do not use a single shared template. The field requirements differ, and a shared template will either miss required fields or collect irrelevant data.
- Map your supply chain data requests to the correct template for each battery type. Suppliers providing data for an LMT battery need to know which fields apply to that category.
- Set up your carbon footprint, recycled content, SVHC, and due diligence processes to feed into both passport types. The methodology can be shared, but the output must be recorded separately for each battery and each passport.
- Confirm your digital passport system can generate and maintain a unique identifier for each individual battery, as required under Article 77(3), separately for each battery type.
- Target internal readiness well before 18 February 2027. The regulation does not provide a grace period after that date for batteries placed on the EU market.
The Unique Identifier Requirement Applies to Both
Article 77(3) requires each battery passport to be linked to a unique identifier for the individual battery. This applies to both EV and LMT batteries. The passport must be accessible via a data carrier, such as a QR code, on the physical battery. The data carrier requirements are set out in Article 77(4).
For LMT batteries, which are produced in higher volumes and at lower unit values than most EV batteries, the operational cost of applying and managing unique identifiers at scale is a real consideration. The regulation does not provide an exemption based on production volume or battery value. Every LMT battery placed on the EU market after 18 February 2027 needs its own passport and its own unique identifier.
What Happens After February 2027
The 18 February 2027 date is confirmed in Article 77 for both EV and LMT batteries. Additional requirements, including the full performance and durability data fields and some supply chain transparency obligations, are subject to delegated acts that the Commission has not yet finalised. The Commission has not published an adoption date for those acts, so no date should be assumed for them. The 18 February 2027 obligation in Article 77(1) is not affected either way. Do not treat any estimated adoption date for those delegated acts as confirmed. The 18 February 2027 obligation itself is confirmed and is not affected by them.
The EU Battery Regulation 2023/1542 compliance timeline means that manufacturers need to be operational with their passport systems by February 2027, not starting to build them. The delegated act requirements that follow will add to an already-live system, not replace the need to have one in place.
If you are ready to see how Traceable handles both EV and LMT battery passports in a single platform, visit traceable.digital/pricing to start a free trial. You can explore the separate templates for each battery type and map your own product range against the field requirements before committing.
