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LMT and e-bike worked record: a battery passport entry for a light means of transport battery

An LMT battery record has no capacity threshold, so the entry turns on correct category assignment, removability context and use history.

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A light means of transport battery, often called an LMT battery, powers a vehicle such as an electric bicycle, an e-moped or an e-scooter. From 18 February 2027, each LMT battery placed on the market or put into service must have a battery passport under Article 77 of Regulation (EU) 2023/1542. There is no capacity threshold for LMT batteries. The worked outline below is illustrative in form only. Placeholder entries mark positions in a record, not values from a real battery, a real bicycle or a real scooter.

Why is there no capacity threshold for LMT batteries?

Article 77 lists LMT batteries without a capacity condition, while industrial batteries are listed only where capacity is greater than 2 kWh. The difference is deliberate in the text and must be preserved in the record. A small LMT battery is not outside the passport duty because the capacity is low. A reader who applies the industrial threshold to an LMT battery will wrongly conclude that no passport is required. The record therefore states the category explicitly as LMT, with the vehicle type or application described in neutral terms, so that the threshold question does not need to be inferred from capacity alone. Category assignment is made at placing on the market and recorded with the model identity. Later use in a different vehicle type does not rewrite the original category entry, although a status change may need to be recorded where the battery is repurposed.

Which model fields matter most for an LMT entry?

Model fields include manufacturer identity, model identifier, LMT category, chemistry, rated capacity and voltage, weight, and the declaration of conformity reference. Performance and durability values for LMT batteries carry particular weight because cycle life and capacity retention shape expectations for everyday use. The entry must show the test conditions behind those values, including the cycle life test and the reference conditions, so that a capacity retention figure is not read as a promise for every pattern of use. Carbon footprint information and recycled content information sit at model level where the relevant duties apply, with timing labelled expected until the delegated act position is settled. The public tier carries the model summary. Detailed composition and dismantling information sit in the authorised tier.

How does removability context appear in the record?

Removability and replaceability duties for LMT batteries sit in Article 11 and in Commission guidance on harmonised application. The passport entry does not itself prove removability, but the entry and the product information together should allow a reader to see whether the battery is presented as removable by an end user, removable with commercially available tools, or removable only through a service route. The record should not claim a removability outcome that the product documentation does not support. Where instructions for removal and replacement are provided online, the passport entry can point to the existence of that information without reproducing it. Confusion arises when a battery that is removable in principle is recorded as if removal required no tools, no instructions and no safety precautions. The entry keeps the factual position separate from any claim about ease of removal.

Which unit history accumulates for an LMT battery?

Unit history for an LMT battery includes the unique identifier, serial number and manufacturing date, followed by dated entries for state of health, repairs, replacements of parts where recorded, and status changes. LMT batteries change hands frequently, through sale, sharing schemes and service, and the record must not assume a single holder for life. Each dated entry needs an actor type and a measurement basis where a value is recorded. Self discharge evolution and remaining capacity are among the state of health parameters that Annex XIII point 4 and Annex VII contemplate for LMT batteries. A single state of health figure without a date, a method and a reference condition is a snapshot without a scale. The history section should show the sequence of snapshots so that change over time can be read, and should show missing periods as missing.

What does the worked LMT entry look like in outline?

Record sectionIllustrative entryNote for the reader
CategoryLMT, vehicle application statedNo capacity threshold applies
Model identityManufacturer, model identifier, chemistry, capacity, voltage, weightPublic tier summary
PerformanceCycle life, capacity retention, test conditionsRead with the stated reference conditions
Unit identityUnique identifier, serial number, manufacturing dateFixed at production
Use historyDated state of health entries, repairs, status changesEach entry dated and sourced
Dismantling and safetyDismantling information and safety measuresAuthorised tier

How should a second hand reader use an LMT entry?

A second hand reader uses the entry to check identity, currency and consistency before any other judgement. Identity is the match between the battery marking, the identifier in the record and the model identifier. Currency is the date of the latest state of health entry and any status change since that date. Consistency is the match between the record, the marking and the declaration reference. A reader should not treat a high state of health figure from an old date as a current figure, and should not treat the absence of a repair entry as proof that no repair occurred unless the system records completeness of repair history. The entry is one source of evidence about the battery. It does not replace inspection, testing or the documentation that accompanies a sale. This guide gives general educational information only and does not give legal advice for a particular battery, vehicle or sale.

Sources & further reading

Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.

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