Spare and replacement batteries

Spare batteries need their own passport

A spare battery sold on its own is placed on the market like any other battery. An LMT battery placed on the market from 18 February 2027 needs its own passport and QR code, whether it ships in a bike or separately.

The passport comes from whoever places the battery on the market: the brand whose name is on it or, for batteries from outside the EU, the importer. A dealer that sells it on doesn’t create one.

The age of the bike doesn’t matter. A new spare battery for a bike sold in 2024 needs a passport if the battery is placed on the market after 18 February 2027.

Swapping a battery during a repair

When a workshop replaces a worn battery with a new one, the new battery comes with the passport its manufacturer or importer created. The workshop doesn’t create one. Once the old battery is discarded it becomes waste, and responsibility for its passport passes to the producer, its producer responsibility organisation or the waste management operator.

Repairing the battery itself

According to the Commission’s FAQ, a repair, such as replacing a faulty cell or connector, doesn’t create a new passport. Remanufacturing does. It means disassembling and evaluating all cells and modules, restoring at least 90% of the original rated capacity, keeping the state of health of all cells within 3% of each other, and using the battery for its original purpose. A remanufactured battery gets a new passport, linked to the original.

Replaceable by an independent professional

From 18 February 2027, Article 11(5) requires anyone who places on the market a product with an LMT battery to make sure that the battery, and the individual cells in it, can readily be removed and replaced by an independent professional during the product’s lifetime. The obligation sits with the e-bike or e-scooter, so with its brand or importer.

Readily replaceable means that another compatible battery can take its place without affecting the functioning, performance or safety of the vehicle. The Commission’s guidelines add that special tools should be available to independent professionals at a reasonable and non-discriminatory price, and that a compatible cell has the same technical parameters, including capacity, state of health, design and chemistry.

An independent professional, in those guidelines, is an independent operator with the technical competence and qualification to repair the product, working on a commercial basis or in commercial premises. For work on cells, that includes the competence to make the battery work as intended again.

Cells or modules: a proposed change

In December 2025 the Commission proposed, as part of Omnibus VIII, that LMT battery packs be replaceable at module level instead of cell level. The proposal is still being negotiated. Until a change is adopted, the rule as written applies from 18 February 2027.

Spare parts for five years

Article 11(7) requires LMT batteries to be available as spare parts for at least five years after the last unit of the vehicle model is placed on the market, at a reasonable and non-discriminatory price for independent professionals and end-users. According to the Commission’s guidelines, this doesn’t apply to products placed on the market before 18 February 2027, and fasteners that can’t be re-used should be available as spare parts too.

No software lock-in

Software must not be used to stop a battery, or its key components, from being replaced by a compatible one (Article 11(8)). The Commission’s guidelines give parts pairing as an example: software that ties a battery to one individual vehicle.