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Batteries and electronics Manufacturer · Importer 6 min read

We sell e-bikes or e-scooters

The traction battery of an e-bike or e-scooter is an LMT battery under the Battery Regulation (EU) 2023/1542: it needs performance and durability documents and state-of-health data now, and from 18 February 2027 a battery passport and replaceability by an independent professional. The vehicle itself needs EMC conformity. First check whether type-approval Regulation (EU) No 168/2013 covers it, because that changes which other rules apply.

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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice

Why this happens

The battery decides much of the paperwork. The Battery Regulation (EU) 2023/1542 defines an LMT battery as a sealed battery of 25 kg or less, specifically designed to provide power for the traction of wheeled vehicles that can be powered by an electric motor alone or by motor and human power, including type-approved L-category vehicles, and that is not an electric vehicle battery (Article 3(1)(11)). The regulation applies from 18 February 2024, its conformity assessment rules from 18 August 2024 and Article 11 on removability from 18 February 2027 (Article 96(2)).[1]

LMT batteries carry obligations that portable batteries do not. Since 18 August 2024 they are accompanied by a document with values for the electrochemical performance and durability parameters of Annex IV (Article 10(1)), and their battery management system contains up-to-date data for determining state of health and expected lifetime (Article 14(1)). From 18 February 2027 they need a battery passport (Article 77(1)), reached through a QR code (Article 13(6)(a)), and anyone placing a product with an LMT battery on the market ensures that the battery and its cells are readily removable and replaceable by an independent professional (Article 11(5)), keeps the battery available as a spare part for five years after the last unit of the model (Article 11(7)) and does not use software to impede replacement (Article 11(8)). Carbon footprint, minimum performance and recycled content duties are phased in later, on dates linked to Commission acts (Articles 7, 8 and 10).[1]

The vehicle is electrical apparatus. Equipment liable to generate or be affected by electromagnetic disturbance must meet the essential requirements of the EMC Directive 2014/30/EU before it is made available (Articles 3(1)(2), 4 and 6).[2]

Whether the vehicle is type-approved matters for the rest. Regulation (EU) No 168/2013 applies to L-category vehicles but excludes, among others, pedal cycles with pedal assistance up to 250 W that cut out at 25 km/h, self-balancing vehicles and vehicles without a seating position (Article 2(2)(h) to (j)). The WEEE Directive excludes means of transport except electric two-wheel vehicles that are not type-approved (Article 2(4)(d)), and RoHS uses the same wording (Article 2(4)(f)). The Machinery Regulation (EU) 2023/1230, applying from 20 January 2027, excludes vehicles within the scope of Regulation (EU) No 168/2013 (Article 2(2)(h) and Article 54).[3][4][5]

Where the specific acts do not cover a risk, the General Product Safety Regulation (EU) 2023/988 applies to the aspects and risks they leave open (Article 2(1)).[6]

How to solve it

  1. Settle whether the vehicle is type-approved or not

    Regulation (EU) No 168/2013 covers L-category vehicles, but excludes pedal cycles with pedal assistance of up to 250 W continuous rated power whose motor cuts out when the rider stops pedalling and before 25 km/h, self-balancing vehicles and vehicles without a seating position. Which side your product falls on decides whether the type-approval rules or the product rules for non-type-approved vehicles apply.

    Regulation guidesKnow-how Free Open

  2. Treat the traction battery as an LMT battery

    A sealed battery of 25 kg or less designed to power the traction of wheeled vehicles driven by an electric motor alone or with human power is an LMT battery. It goes through conformity assessment under Article 17 of the Battery Regulation, which applies from 18 August 2024, and from that date it is accompanied by a document with its electrochemical performance and durability values.

  3. Check the battery management system data

    Since 18 August 2024 the battery management system of an LMT battery contains up-to-date data for the parameters that determine its state of health and expected lifetime, as listed in Annex VII of the Battery Regulation.

  4. Design for replacement by an independent professional

    From 18 February 2027, whoever places on the market a product with an LMT battery ensures that the battery and its individual cells are readily removable and replaceable by an independent professional, that the battery is available as a spare part for five years after the last unit of the model, and that no software blocks replacement with a compatible battery.

  5. Prepare the battery passport and the QR code

    From 18 February 2027 each LMT battery placed on the market has a battery passport, reached through a QR code on the battery. The economic operator placing it on the market keeps the information accurate, complete and up to date.

  6. Cover EMC, WEEE and RoHS for the vehicle and charger

    The vehicle and its charger are apparatus under the EMC Directive. Electric two-wheel vehicles that are not type-approved are not excluded from WEEE and RoHS, so the producer registration, take-back and substance restrictions apply to them. Sign one declaration naming every act concerned.

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What you need to show

DocumentWhere it comes fromLegal ground
Performance and durability document for the LMT batteryThe battery manufacturerBattery Regulation Article 10(1) and Annex IV, Part A
EU declaration of conformity for the vehicle (EMC, and RoHS where it applies)The vehicle manufacturerEMC Directive Articles 7(2) and 15; RoHS Directive Article 13
Battery passport, from 18 February 2027The economic operator placing the battery on the marketBattery Regulation Article 77(1) and (4)
WEEE producer registration where the vehicle is in scopeYou, or your authorised representativeWEEE Directive Articles 2(4)(d) and 16

If you do nothing

Authorities can order withdrawal or recall

Where an authority has sufficient reason to believe that apparatus presents a risk and finds that it does not comply with the EMC Directive, it requires corrective action, withdrawal or recall within a reasonable period, and takes provisional measures if the operator does not act (EMC Directive Article 38(1) and (4)). Formal non-compliance is dealt with under Article 40.[2]

Safety gaps fall back on the GPSR

Where specific Union safety rules cover only some risks of a product, the General Product Safety Regulation applies to the aspects and risks those rules do not cover (Regulation (EU) 2023/988, Article 2(1)).[6]

Penalties under national law

Member States lay down effective, proportionate and dissuasive penalties for infringements of the EMC rules, which may include criminal penalties for serious infringements (EMC Directive Article 42).[2]

Questions about this problem

Is a pedelec a motor vehicle that needs type-approval?

Not if it is a pedal cycle with pedal assistance whose auxiliary motor has a maximum continuous rated power of 250 W or less, cuts out when the cyclist stops pedalling and is cut off before 25 km/h. Those are excluded from Regulation (EU) No 168/2013 (Article 2(2)(h)).

Must the rider be able to change the battery?

For LMT batteries, the Battery Regulation requires that the battery and its cells are readily removable and replaceable by an independent professional, not by the end-user, from 18 February 2027 (Article 11(5) and Article 96(2)(a)).

Do WEEE and RoHS apply to e-bikes?

Both directives exclude means of transport, but not electric two-wheel vehicles that are not type-approved (WEEE Directive Article 2(4)(d); RoHS Directive Article 2(4)(f)). A non-type-approved e-bike or two-wheel e-scooter is therefore not excluded as a means of transport, and is in scope where it is electrical and electronic equipment.

Will the machinery rules apply?

The Machinery Regulation (EU) 2023/1230, applying from 20 January 2027, excludes two- or three-wheel vehicles within the scope of Regulation (EU) No 168/2013 (Article 2(2)(h)). A product outside that regulation is not covered by this exclusion, so check it against the machinery definitions. Until 20 January 2027 the Machinery Directive 2006/42/EC applies; its Article 1(2)(e) excludes vehicles covered by Directive 2002/24/EC, the predecessor of Regulation (EU) No 168/2013.

Do ecodesign rules cover e-bikes?

E-bikes and e-scooters are not excluded from the Ecodesign Regulation (EU) 2024/1781 (recital 13), but requirements only arise when a delegated act sets them for a product group (Article 4).

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Related problems

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Regulations involved

BattREMCRoHSWEEE

Sources

  1. Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026) EUR-Lex · accessed 4 October 2026
  2. Directive 2014/30/EU on electromagnetic compatibility (consolidated text of 30 May 2026) EUR-Lex · accessed 4 October 2026
  3. Regulation (EU) No 168/2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles EUR-Lex · accessed 4 October 2026
  4. Directive 2012/19/EU on waste electrical and electronic equipment (consolidated text of 8 April 2024) EUR-Lex · accessed 4 October 2026
  5. Regulation (EU) 2023/1230 on machinery EUR-Lex · accessed 4 October 2026
  6. Regulation (EU) 2023/988 on general product safety EUR-Lex · accessed 4 October 2026
  7. Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products EUR-Lex · accessed 4 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
5 October 2026

General information, not legal advice. Check the legal text or ask an adviser about your own product.

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Cite this page 
Conphora (2026). We sell e-bikes or e-scooters. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/e-bike-e-scooter/
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