Batteries already in stock on 18 February 2027

The rule

Article 77(1) of the Batteries Regulation requires a passport for each LMT battery placed on the market or put into service from 18 February 2027. Placing on the market means making a battery available on the EU market for the first time.

That moment counts per battery, not per model. The Commission’s Blue Guide on EU product rules explains that each individual product is placed on the market only once, and that units placed on the market after new requirements apply must meet them, even when the same model was sold before.

Already supplied: no passport

A battery that the manufacturer or importer supplied to a dealer, distributor or customer before 18 February 2027 has been placed on the market. It doesn’t need a passport, and the dealer can still sell it after that date.

Supplying means an offer or agreement to transfer the battery once it has been made, such as a sale. The battery doesn’t have to be delivered yet. An order for batteries that haven’t been made yet doesn’t count.

Still in your own warehouse: passport needed

Batteries that a brand or importer still holds on 18 February 2027 haven’t been placed on the market. Each one needs a passport, and the QR code that leads to it, when it is supplied after that date.

Imports and stock in transit

For batteries from outside the EU, placing on the market generally happens when they are declared for release for free circulation at customs, according to the Blue Guide. A shipment that clears customs after 18 February 2027 needs passports, even if it was ordered or shipped earlier. Goods in transit, in a customs warehouse or in a free zone haven’t been placed on the market yet.

Batteries in imported e-bikes or e-scooters are normally placed on the market when the vehicle is imported, and the importer provides their passports.

Batteries in bikes

The same goes for a battery inside a bike: what counts is when that bike is first supplied in the EU. Bikes supplied to dealers before 18 February 2027 can be sold without passports for their batteries. Bikes that the brand still holds on that date need one for each battery.

Online sales

Batteries offered online count as made available in the EU when the offer targets buyers in the EU, for example through delivery options, languages or payment methods. A webshop outside the EU that targets EU customers falls under the same rules.

Used and remanufactured batteries

• A used battery brought in from outside the EU is placed on the market when it first enters the EU. After 18 February 2027 it needs a passport like a new one.

• A battery remanufactured or repurposed after 18 February 2027 needs a new passport, even if the original was placed on the market earlier and has none. The Commission’s FAQ confirms this.

Other rules that start on the same date

The QR code on every battery and the replaceability rules for products with LMT batteries also start on 18 February 2027, and they also apply to what is placed on the market from that date. According to the Commission’s guidelines, the five-year spare parts rule doesn’t apply to products placed on the market before it.

What to do now

• Count the batteries and bikes you expect to hold on 18 February 2027, spare batteries included

• Keep the invoices and delivery notes that show when each batch was supplied

• Plan shipments from outside the EU by their customs date, not their order date

• Make sure batteries supplied from that date leave with a QR label and a live passport