Battery Passport -
Batteries in Scope
Not all batteries are subject to Battery Passport obligations.
Scope is determined by battery category, capacity, and whether the battery is placed on the EU market or put into service.
This page provides practical decision logic to determine whether your batteries are in scope.
The trigger question
Are you placing a battery on the EU market or putting it into service?
- Selling batteries or battery-containing products into the EU triggers scope.
- Importing batteries into the EU triggers scope.
- Placing batteries under your brand name triggers scope.
Battery categories in scope
| Battery category |
In scope |
Notes |
| Electric vehicle batteries |
Yes |
Applies to traction batteries for road vehicles |
| Industrial batteries* |
Yes, if capacity > 2 kWh |
Includes stationary and many non-road applications |
| LMT batteries |
Yes |
Light means of transport such as e-bikes and e-scooters |
| Portable batteries |
No |
Not subject to battery passport requirements |
* Consumer power banks/stations and lawnmower equipment using batteries above 2 kWh are classified as industrial batteries and are subject to Battery Passport requirements from 18 February 2027.
NOTE: SLI batteries and portable batteries are not subject to Battery Passport requirements but remain fully subject to safety, labeling, EPR, and recycling obligations under Regulation (EU) 2023/1542.
Capacity thresholds
| Battery type |
Capacity rule |
Practical impact |
| Industrial batteries |
> 2 kWh |
Below threshold batteries are out of passport scope |
| EV and LMT batteries |
No minimum capacity threshold |
All qualifying batteries are in scope |
Placing on the market vs putting into service
| Concept |
What it means |
Why it matters |
| Placing on the market |
First making a battery available in the EU |
Triggers most regulatory obligations |
| Putting into service |
First use of a battery in the EU |
Covers certain non-sale deployment models |
Common edge cases
| Scenario |
Likely outcome |
Reason |
| Battery embedded in equipment |
In scope |
Obligations attach to the battery, not the enclosure |
| Second-life batteries |
Often in scope |
Depends on whether placed on the market again |
| Replacement batteries |
In scope |
Treated as new market placement |
| Export-only products |
Out of scope |
EU rules apply only to EU market placement |
Minimum scope determination checklist
| Question |
If yes |
Next step |
| Do you place batteries on the EU market |
You are an obligated economic operator |
Identify battery categories |
| Is the battery EV, LMT, or industrial > 2 kWh |
Battery passport applies |
Prepare identity and data requirements |
| Is the battery portable |
Passport does not apply |
Confirm other obligations still apply |
Where to go next
Disclaimer.
Informational guidance only.
Not legal advice.
Always validate scope determinations against the official regulation text.
