The other battery rules

This page covers the battery. The e-bike or e-scooter itself has its own product rules.

Conformity and CE marking, since 18 August 2024

• Carry out the conformity assessment. For LMT batteries that is usually internal production control (Module A), without a notified body

• Draw up the technical documentation: a description of the battery, drawings, the standards applied, calculations, test reports and a specimen of the label

• Draw up an EU declaration of conformity for each battery model

• Affix the CE marking to each battery

• Keep the documentation and the declaration for 10 years after the last battery of the model is placed on the market

On the battery

• The model and a batch or serial number

• The manufacturer’s name or trademark, postal address and, if available, website and email

• For imported batteries, the importer’s name and address as well

• Instructions and safety information in a language that end-users in the country of sale understand

• The crossed-out wheeled bin for separate collection, since 18 August 2025

• The QR code that opens the passport, from 18 February 2027

A label with the capacity and other general information follows 18 months after the Commission adopts its implementing act on labels, which it hasn’t done yet.

Performance, durability and state of health

Since 18 August 2024, every LMT battery has had to come with a document giving its electrochemical performance and durability values (Article 10 and Annex IV). Its battery management system has had to hold up-to-date state-of-health and lifetime data, with read-only access for the buyer and independent operators (Article 14). Minimum performance values for LMT batteries follow from 18 August 2028 at the earliest.

Substances

On top of the REACH restrictions, Annex I limits substances in batteries. Mercury, for example, may not exceed 0.0005% by weight in any battery.

Producer registration and take-back, since 18 August 2025

The rules on extended producer responsibility apply since 18 August 2025. In each Member State, the producer is whoever first makes a battery available there, including batteries inside e-bikes and e-scooters. That can be the brand, the importer, or a company bringing batteries in from another Member State.

• Register as a producer in each Member State where you make batteries available for the first time. Without registration you may not sell them there

• Finance the collection, transport and treatment of waste batteries, alone or through a producer responsibility organisation

• Take back waste LMT batteries free of charge, whatever their brand, through a collection system with collection points

• Tell end-users, at the point of sale and online, how to prevent waste, where to hand in batteries and what the symbols mean

• Selling directly to end-users in a Member State where you are not established? Appoint an authorised representative for producer responsibility there

Each Member State keeps its own register of producers, with its own procedure.

Replaceability and spare parts, from 18 February 2027

Products with LMT batteries must let an independent professional remove and replace the battery and its cells, and the batteries must stay available as spare parts for five years. The guide on spare and replacement batteries has the details.

Due diligence, for large companies only

Due diligence on cobalt, natural graphite, lithium and nickel starts on 18 August 2027 and applies only to companies with a net turnover of EUR 40 million or more, or part of a group above that. A provisional EU agreement would raise this to EUR 200 million.