LMT Batteries — Light Means of Transport
LMT batteries are used in e-bikes, e-scooters, electric mopeds, and other light electric vehicles. The battery passport obligation for LMT batteries applies from 18 February 2027 under Article 77(1); it is not yet in force. Other obligations (carbon footprint, due diligence, recycled content) apply on their own dates, set out below, and several depend on delegated or implementing acts not yet adopted.
This documentation is provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
Definition
LMT batteries are defined in Article 3(1)(11) of the regulation as batteries that are sealed, weigh 25 kg or less, and are specifically designed to provide electric power for the traction of wheeled vehicles that can be powered by the electric motor alone or by a combination of motor and human power (including vehicles of type-approval category L under Regulation (EU) 168/2013), and that are not EV batteries. A category-L battery weighing more than 25 kg is an EV battery, not an LMT battery.
EU vehicle category L — included vehicle types
| EU Category | Description | Battery Application |
|---|---|---|
| L1e-A | Powered cycles (motor assistance only, e.g. e-bikes with motor ≤1 kW) | Pedelec and EPAC batteries |
| L1e-B | Speed pedelecs (motor assistance above 25 km/h, ≤45 km/h) | Speed pedelec batteries |
| L2e | Two-wheel mopeds | Electric moped batteries |
| L3e | Two-wheel motorcycles | Electric motorcycle batteries |
| L4e | Motorcycles with sidecar | Electric motorcycle batteries |
| L5e | Motorised tricycles | Three-wheel electric vehicle batteries |
| L6e | Light quadricycles (≤45 km/h) | Small electric micro-car batteries |
| L7e | Heavy quadricycles | Larger electric quadricycle batteries |
Important note on standard e-bikes (EPAC)
Standard e-bikes (electrically power-assisted cycles, EPAC) compliant with EN 15194 — those with motor assistance limited to 25 km/h and motor power ≤250 W — are not required to be type-approved under Regulation (EU) 168/2013. Despite the absence of a type-approval obligation, batteries in these bicycles fall within the LMT definition itself, which covers batteries for "wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, including type-approved vehicles of category L" (Article 3(1), point (11)), where the battery is sealed, weighs 25 kg or less and is not an EV battery. Manufacturers of standard e-bike batteries should treat their products as LMT batteries for DPP purposes.
Battery Passport Date: 18 February 2027
The LMT battery passport obligation applies from 18 February 2027 under Article 77(1) — the same single start date as EV batteries and industrial batteries above 2 kWh. It is not yet in force. Every LMT battery placed on the market or put into service on or after that date must have a battery passport, created before the battery is placed on the market. Operators in scope should prepare their product data now, but no battery passport is legally required before 18 February 2027.
Key Requirements
Battery Identification
Every LMT battery DPP must uniquely identify the battery:
| Field | Requirement |
|---|---|
| Manufacturer name and address | Full legal name and registered address |
| Battery model identifier | Model name or designation |
| Battery serial number | Unique identifier attributed to the individual battery (Article 77(3)) |
| Date of manufacture | Month and year |
| Battery category | Must be declared as "LMT" |
Chemistry and Specifications
| Field | Requirement |
|---|---|
| Cell chemistry | Active cathode and anode materials (e.g. NMC/graphite, LFP/graphite) |
| Rated capacity | Capacity in Ah at defined conditions |
| Nominal voltage | Operating voltage (V) |
| Energy content | Total energy in Wh or kWh |
| Operating temperature range | Min/max temperature for rated operation |
Safety Testing — UN 38.3
LMT batteries are subject to UN 38.3 transport safety testing (the UN Manual of Tests and Criteria, Part III, subsection 38.3). This test suite — covering altitude simulation, thermal cycling, vibration, shock, external short circuit, crush, overcharge, and forced discharge — must be completed before the battery can be transported by air, sea, or road under dangerous goods regulations.
The Regulation does not require UN 38.3 information in the battery passport. The Traceable LMT template has optional fields for the UN 38.3 test report and the UN 38.3 test date.
Recycled Content Declarations
Recycled content is governed by Article 8, and LMT batteries are in scope alongside EV, industrial (>2 kWh) and SLI batteries. For LMT batteries, the recycled-content declaration is required from 18 August 2033 (Article 8(1), second subparagraph). LMT batteries are not in the first-tier minimum shares (18 August 2031) but are in the second-tier minimum shares from 18 August 2036 (26% cobalt, 85% lead, 12% lithium, 15% nickel). The figures for cobalt, lithium, nickel and lead are set in Article 8(3); consult the current Official Journal text for the values applicable to each material and date.
Carbon Footprint
Under Article 7(1), second subparagraph, point (c), the LMT carbon footprint declaration applies from 18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest. The carbon footprint performance class also applies to LMT batteries, alongside EV and industrial batteries, under Article 7(2), third subparagraph, point (c): from 18 February 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest. The Regulation does not fix the number of classes; they are established by Commission delegated act under Article 7(2), fourth subparagraph, point (a), and Annex II, point 8, requires that "a meaningful number of classes of performance shall be identified, with category A being the best class". LMT batteries are not exempt from the performance-class requirement.
Each date is the later of the fixed date and 18 months after the entry into force of the delegated act or of the implementing act referred to in the fourth subparagraph of Article 7(1) or Article 7(2) respectively.
Traceable's LMT template includes carbon footprint fields; the platform treats them as optional and they do not block publication. The platform records 18 August 2028 as the date its LMT carbon-footprint value checks start to block. The statutory LMT declaration date under Article 7(1), second subparagraph, point (c), is 18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest. This is not a compliance guarantee.
QR Code and Data Carrier
The battery passport must be accessible through the QR code referred to in Article 13(6) (Article 77(3)), as described in Annex VI Part C. For LMT batteries, which are often consumer-facing products, it is particularly important that:
- The QR code is on the battery itself, not merely on the box
- The QR code remains scannable after the battery is installed in the vehicle (relevant where batteries are installed inside e-bike frames)
- The public DPP viewer is mobile-optimised, as end consumers are likely to scan the code with a smartphone
Traceable Fields: Mandatory vs Recommended for LMT
Mandatory fields in the Traceable LMT template
All fields marked with a red asterisk in the Traceable LMT DPP Builder are mandatory. These include the core identity fields, chemistry, rated capacity, nominal, minimum and maximum voltage, internal resistance, cycle life, calendar life, dismantling information and the other data points the Commission's guidance marks Mandatory. The UN 38.3 test report and date, the safety certification standard, the recycled content fields and the carbon footprint fields are optional.
Recommended fields (marked as advisory in Traceable)
Traceable recommends populating the following information; the rationale states where the Regulation or the Traceable LMT template already requires it:
| Field | Rationale for Recommendation |
|---|---|
| Cycle life | Required in the battery passport: "expected battery lifetime expressed in cycles, and reference test used" (Annex XIII, point 1(j)); a required field in the Traceable LMT template |
| Calendar life | Required under Article 10(1): the expected life-time "in terms of cycles, except for non-cycle applications, and calendar years" (Annex IV, Part A, point 5); a required field in the Traceable LMT template |
| Dismantling instructions | Required in the battery passport for persons with a legitimate interest: "dismantling information" (Annex XIII, point 2(c)); a required field (Dismantling Guide) in the Traceable LMT template |
| Applicable safety standards (IEC 62133, EN 50604-1) | Supports market surveillance verification; the Traceable LMT template has an optional Safety Certification Standard field |
| Operating temperature range | Important for consumer safety in extreme climates |
Common Data Gaps for LMT Battery Operators
Based on common patterns, operators placing LMT batteries on the EU market frequently face the following challenges:
UN 38.3 test documentation: Many small-volume e-bike battery manufacturers rely on test reports obtained by their cell supplier rather than conducting full pack-level testing. Market surveillance authorities expect pack-level UN 38.3 test reports in addition to cell-level data. Verify that your test documentation covers the assembled battery pack as shipped.
Serial number implementation: Many e-bike batteries are not serialised at the unit level — the same label appears on all units in a production run. The regulation requires individual battery identification. If unit-level serialisation is not currently implemented, plan to introduce it: from 18 February 2027 each LMT battery placed on the market or put into service must have its own battery passport (Article 77(1)), reached through a QR code that links to a unique identifier attributed to that battery (Article 77(3)).
Recycled content data from suppliers: LMT battery suppliers, particularly those based outside the EU, may not have recycled content data available at the material level. If your supplier cannot provide cobalt, nickel, and lithium recycled content percentages, do not estimate or carry forward figures from other products: the documentation is "for each battery model per year and per manufacturing plant" (Article 8(1)), and for LMT batteries it applies from 18 August 2033.
QR code placement on installed batteries: For batteries installed inside e-bike frames or under the seat of an e-scooter, the QR code may not be physically accessible after installation. Ensure the QR code is affixed to an accessible location or, at minimum, to the battery housing in a way that remains visible during normal maintenance.
Safety Note: Consumer Use Context
LMT batteries are consumer-facing products. E-bike and e-scooter batteries have been the subject of significant fire incidents across multiple EU member states, driven by the use of substandard batteries in informal market channels, improper charging practices, and counterfeit products.
For LMT batteries, Traceable recommends that the public-facing DPP prominently includes:
- Safe charging instructions (maximum charge current, recommended charger type, avoid overnight charging in enclosed spaces)
- Storage safety guidance (temperature, state of charge for storage)
- Physical damage guidance (do not use battery if dropped or physically damaged)
- Emergency contact for battery-related incidents
This information is not strictly required by the regulation text but is in line with the regulation's consumer protection objectives and reduces operator liability in the event of a consumer incident.