LMT Batteries (Light Means of Transport) under the EU Battery Regulation: Definition, Obligations and Deadlines

The definition sits in Regulation (EU) 2023/1542 (OJ L 191, 28.7.2023), in force since 17 August 2023 (Article 96(1)) and applicable since 18 February 2024 (Article 96(2)). LMT batteries form one of the five categories of Article 1(3) of the EU Battery Regulation.

Each LMT obligation runs on its own date, and the carbon footprint steps, the minimum performance values and the general and capacity labels depend on Commission acts not adopted as of 13 November 2026. The sections below cover the definition and its boundaries, the obligations with their dates, producer responsibility and repurposing.

What Is an LMT Battery?

An LMT battery is the traction battery of an e-bike, an e-scooter or another light wheeled vehicle, which recital 15 of the Regulation names as examples, provided it is sealed and weighs 25 kg or less.

The category is new. The repealed Directive 2006/66/EC knew three categories (portable, automotive, industrial), and the Commission proposal COM(2020) 798 still counted these batteries as portable. The German text of the Regulation calls them "Batterie für leichte Verkehrsmittel" (LV-Batterie), one of the five battery categories under the EU Battery Regulation.

The Four Conditions of the Legal Definition

The definition sets four cumulative conditions: the battery is sealed, weighs 25 kg or less, is specifically designed to power the traction of wheeled vehicles moved by an electric motor alone or by motor and human power, and is not an electric vehicle battery.

Table 1: The four conditions; the other Article 3(1) terms are collected under battery regulation definitions.

The words "including type-approved vehicles of category L" widen the vehicle range to Regulation (EU) No 168/2013 vehicles without limiting it to them. The adopted text has no motor-power cap, while COM(2020) 798 required an electric motor of less than 750 watts.

Where the LMT Category Ends: Portable, EV and Industrial Batteries

Weight decides the line to electric vehicle batteries: a traction battery of a category L vehicle that weighs more than 25 kg is an electric vehicle battery under Article 3(1), point (14), while the same battery at 25 kg or less is an LMT battery.

Recital 15 draws the other lines: traction batteries of toy vehicles are portable, and those for rail, waterborne, aviation and off-road machinery are industrial, because classification follows design and use, not chemistry (recital 15). The repealed Batteries Directive 2006/66/EC no longer governs any of them.

Cells or modules made available for end use without further assembly are batteries (Article 1(4)) and follow the most similar category, the strictest where several fit. The strictest-category rule of Article 1(3), second subparagraph, serves Chapter II only, never producer responsibility or labelling. The table maps seven batteries to their category.

Which Obligations Apply to LMT Batteries?

LMT batteries carry most of the product obligations of the Regulation: a carbon footprint declaration, recycled content documentation, performance documentation, battery management data, removability, a capacity label, a QR code and a battery passport, plus due diligence and producer responsibility.

Article 1(3) applies regardless of incorporation, and the producer definition of Article 3(1), point (47), covers batteries incorporated in light means of transport (consolidated text), so each obligation attaches to the battery sold alone or inside a vehicle. Article 12 safety rules concern stationary storage only.

Table 2: LMT obligations; all requirements by article are under EU Battery Regulation requirements.

LMT Battery Deadlines from 2024 to 2036

LMT obligations run on fixed dates from 18 August 2024 to 18 August 2036, while the carbon footprint steps, the minimum performance values and the general and capacity labels run on conditional dates that depend on a secondary act. Every other date of the act is in the EU Battery Regulation timeline.

Table 3: LMT deadlines; secondary-act status is under battery regulation delegated acts.

Product Requirements for LMT Batteries

The product requirements of Chapters II and III apply to each LMT battery placed on the market or put into service, and the manufacturer proves them in the technical documentation and the EU declaration of conformity.

The economic-operator obligations of Chapter VI, Articles 38 to 46, have applied since 18 August 2024 (Article 96(2), point (b)).

Carbon Footprint Declaration, Class and Threshold for LMT Batteries

LMT batteries need a carbon footprint declaration from 18 August 2028 or 18 months after the date of entry into force of the delegated act and the implementing act under Article 7(1), whichever is the latest.

The class follows from 18 February 2030 or 18 months after the classes and label acts, whichever is the latest (Article 7(2)).

The maximum threshold follows from 18 August 2031 or 18 months after the threshold delegated act, whichever is the latest (Article 7(3)).

The Commission owes the classes act by 18 August 2028 and the threshold act by 18 February 2030; no LMT act under Article 7 had been adopted as of 13 November 2026 (see carbon footprint declaration).

Recycled Content in LMT Batteries from 2033 and 2036

LMT batteries that contain cobalt, lead, lithium or nickel in active materials must be accompanied by recycled content documentation from 18 August 2033 (Article 8(1), second subparagraph).

Minimum shares follow only from 18 August 2036: 26 % cobalt, 85 % lead, 12 % lithium and 15 % nickel (Article 8(3)); the earlier shares of Article 8(2) do not cover LMT batteries.

Performance Documentation and Battery Management Data

Since 18 August 2024 the technical documentation of every LMT battery must state the electrochemical performance and durability values of Annex IV, Part A (Article 10(1)), and its battery management system must hold up-to-date state-of-health data (Article 14(1)). Read access and parameters are explained under battery management system rules.

Minimum values follow from 18 August 2028 or 18 months after the entry into force of the delegated act under Article 10(5), second subparagraph, whichever is the latest (Article 10(3)). Annex VII, Part A, lists the LMT state-of-health parameters, such as remaining capacity and the evolution of self-discharging rates.

Removal and Replacement by an Independent Professional

From 18 February 2027 anyone who places on the market a product that incorporates an LMT battery must ensure that the battery and the individual cells in the pack are readily removable and replaceable by an independent professional at any time during the product's lifetime (Article 11(5)).

"Readily replaceable" means that, once removed, the battery can be substituted by another compatible battery without affecting the functioning, performance or safety of the light means of transport (Article 11(6)). Software may not be used to impede that replacement (Article 11(8)). Module-level replacement is only proposed, and the full rules are under removability and replaceability.

Labels and the QR Code on LMT Batteries

LMT batteries have carried the separate collection symbol since 18 August 2025 (Article 13(4)), take a general information label and a capacity label from 18 August 2026 or 18 months after the implementing act under Article 13(10), whichever is the latest, and from 18 February 2027 carry a QR code that opens the battery passport (Article 13(6)(a)).

Due Diligence Obligations for LMT Battery Makers

Chapter VII covers every battery category, so an economic operator placing LMT batteries on the market runs battery due diligence from 18 August 2027 (Article 48(1), as amended by Regulation (EU) 2025/1561) unless Article 47 exempts it: operators below EUR 40 million net turnover that are not part of a group exceeding that figure on a consolidated basis.

Producer Responsibility, Take-Back and Collection of Waste LMT Batteries

Since 18 August 2025 a producer may make LMT batteries available in a member state only once it, or its EPR authorised representative, is registered there, declaring the LMT category in the register (Article 55(2) and (3)(c)). Each member state keeps its own register, as set out under battery producer registration.

A producer under Article 3(1), point (47)(d), selling by distance contracts directly to end-users from another member state or a third country appoints an EPR authorised representative in each member state of sale (Article 56(3)). Distributors take back waste LMT batteries free of charge "at or in the vicinity" of the outlet (Article 62(1)(b)).

Producers or their producer responsibility organisations must attain collection rates of 51 % by 31 December 2028 and 61 % by 31 December 2031 (Article 60(3)).

As of 13 November 2026, Italy excludes individual producer responsibility for LMT batteries (D.Lgs. 29/2026, in force since 7 March 2026, Article 26(1)), and Estonia extended its producer organisation duty to them from 1 January 2026.

When an LMT Battery Changes Category

An LMT battery that is repurposed for stationary storage stops being an LMT battery: a battery intended for industrial uses after repurposing is an industrial battery under Article 3(1), point (13), and Article 45(2) requires compliance taking into account that the battery may fall under a different category.

A repurposed battery is placed on the market anew (recital 16), carries new labels with change-of-status information (Article 13(9)) and receives a new passport linked to the original one (Article 77(7)). Articles 7(5), 8(4), 10(4) and 47, second paragraph, spare batteries already placed on the market before the obligation applied, as explained for second-life batteries.

How to Meet the LMT Battery Obligations

Start with the category, because every later step depends on whether the battery is an LMT battery or an electric vehicle, portable or industrial battery. The six steps below follow that order.

1. Confirm which battery category applies under the four conditions.
2. List the duties by date from the two tables above.
3. Document the Annex IV values, battery management data and labels under Module A or D1 of the battery conformity assessment.
4. Register as one of the producers in each member state of sale.
5. Prepare removability and the passport data for 18 February 2027.
6. Plan due diligence for 18 August 2027 and the carbon footprint declaration.

Recital 11 protects stock: it states that batteries placed in stock in the Union by distributors before the date of application of a requirement do not need to meet it. The manufacturer keeps the EU declaration of conformity and the technical documentation for 10 years (Article 38(4)).

Need help with LMT battery compliance? The full sequence is set out under the battery regulation compliance programme.

Pending Changes and the Review of the LMT Definition

Two pending proposals would touch LMT batteries: COM(2025) 981 of 10 December 2025 (procedure 2025/0397(COD)) would make LMT batteries replaceable at module level instead of cell level, and as of 13 November 2026 it awaits a committee decision in the Parliament's ENVI committee, with plenary indicated for 14 December 2026.

The procedure file is on OEIL. The second proposal, COM(2025) 501, would change the Article 47 due diligence threshold; its agreed text was approved in committee on 2 July 2026, with plenary indicated for 23 November 2026, as of 13 November 2026.

Separately, Article 94(5) requires a Commission report by 30 June 2031 on extending the LMT definition, in particular to non-wheeled vehicles. Until an amending act is published in the Official Journal, the cell-level rule of Article 11(5) stays as adopted. Both proposals are tracked under battery regulation amendments.

LMT Battery Questions

Four questions recur about LMT batteries under the Regulation.

What does LMT stand for on a battery?

LMT stands for light means of transport, the battery category of Article 3(1), point (11), of Regulation (EU) 2023/1542 for sealed traction batteries of 25 kg or less. Producers declare it as a category when they register (Article 55(3)(c)).

Is an e-bike or e-scooter battery an LMT battery?

Yes, if it is sealed and weighs 25 kg or less: recital 15 names e-bikes and e-scooters as light means of transport. A category L traction battery of more than 25 kg is an electric vehicle battery under Article 3(1), point (14).

Does every LMT battery need a passport from 2027?

Yes: Article 77(1) requires a battery passport for each LMT battery placed on the market or put into service from 18 February 2027, with no capacity threshold. Scope, contents and access rules are explained on the EU battery passport page.

Is the battery of a ride-on toy car an LMT battery?

No: recital 15 classes the traction batteries of wheeled vehicles that are toys under Directive 2009/48/EC as portable batteries. The portable rules then apply, including end-user removability under Article 11(1), not the LMT rules.