The EU Battery Regulation (EUBR) is here. Are e-bike and scooter OEMs ready?

The EU Battery Regulation (EUBR), Regulation (EU) 2023/1542, was published on July 28, 2023, to enforce a circular, sustainable lifecycle for all batteries entering the European market. It created sweeping requirements for EV supply chains, ranging from mandatory carbon footprint declarations to the implementation of Digital Battery Passports, effectively making responsible sourcing a legal obligation rather than a voluntary sustainability pledge.

However, while public scrutiny is largely focused on passenger cars, the electric two-wheeler market faces equally stringent rules. Depending on the weight of the vehicle battery, electric motorbikes and scooters fall under either the Light Means of Transport (LMT) category or the broader Electric Vehicle (EV) category. Ultimately, the compliance deadlines that apply depend on how the vehicle’s battery is classified, and on the role of the economic operator placing the product on the market.

Determining Your Classification: EV vs. LMT

Although these vehicles share two wheels, compliance roadmaps diverge significantly. Specific reporting deadlines and design requirements, such as mandates for battery removability, depend entirely on model configurations and classifications. Electric two-wheelers fall into two primary categories: Electric Vehicles (EVs) and Light Means of Transport (LMTs).

High-Power Electric Vehicles (EVs)
Large, high-performance electric motorcycles, including models from manufacturers like BMW, LiveWire, Zero, and Energica, are typically classified as Electric Vehicles (EVs). Because their traction batteries typically weigh more than 25 kg, they fall into the same EV battery category as electric cars.

Electric vehicle batteries are first in line for several requirements. Carbon footprint declarations were originally scheduled for February 2025, but will now apply 12 months after the European Commission adopts the calculation methodology, which is still pending.

Light Means of Transport (LMTs)
Conversely, smaller and lightweight electric vehicles, including commuter scooters from Segway and Xiaomi, shared fleet scooters from Voi and Lime, e-bikes, and lightweight mopeds, typically use batteries classified as Light Means of Transport (LMT) batteries. These vehicles benefit from an extended transition period, with Carbon Footprint declarations applying from August 2028 at the earliest.

How the EUBR Classifies Two-Wheeler Batteries

Since the EUBR applies different deadlines and design mandates to each battery category, accurate classification is the critical first step. Under Article 3 of the Regulation, the test is set by the battery itself, not by the vehicle’s top speed, market segment or charging method:

• LMT battery: a sealed battery weighing 25 kg or less, designed to power the traction of wheeled vehicles that can be driven by an electric motor alone or by a combination of motor and human power – including type-approved L-category vehicles – and that is not an EV battery.

• EV battery: a battery specifically designed to provide traction power to an L-category vehicle that weighs more than 25 kg, or to provide traction to passenger cars and commercial vehicles.

Removability is not part of the test; it is a consequence of the classification. Once a battery is classified as an LMT battery, it must be replaceable by an independent professional from 18 February 2027.

Grey areas

Borderline cases are most likely where a battery pack sits close to the 25 kg threshold, where a vehicle uses more than one battery pack, or where it is unclear whether a battery counts as sealed. In these cases, a regulatory or legal specialist can help confirm the classification before a compliance roadmap is set.

The Risk of Misclassification

Under the EUBR, battery categories are legal definitions based on the battery’s weight, design and the type of vehicle it powers – not a choice for the manufacturer. Treating an LMT battery as an EV battery, or vice versa, risks applying the wrong requirements and deadlines – for example, missing the February 2027 replaceability requirement that applies only to LMT batteries. Where a product sits in a grey area, a regulatory specialist can help confirm the classification before compliance roadmaps are established.

Your EUBR Roadmap: Understanding the Requirements and Your Category

Classification serves as the initial step, followed by the alignment of hardware, supply chains, and data tracking systems with the EUBR framework.

A consolidated compliance timeline matrix for electric vehicle and light means of transport categories outlines the phased requirements across the core regulatory pillars.

EV vs. LMT Compliance Deadlines & Deliverables

* Small and medium-sized enterprise (SME) exemption: Economic operators with a net annual turnover below €40 million in the preceding financial year, and that are not part of a group exceeding that threshold on a consolidated basis, are exempt from the EUBR due diligence obligations (policy, third-party verification and reporting). All other requirements – including carbon footprint, battery passport and replaceability – apply regardless of company size, to the battery categories they cover.

**Carbon footprint dates apply from the date shown or 12–18 months after the Commission adopts the calculation methodology, whichever is later. As of September 2026, the methodology has not been adopted.

Navigating EUBR mandates, from generating verified carbon footprint declarations to launching digital battery passports, requires a degree of supply chain visibility that most manufacturers are actively developing.

TDi Sustainability bridges that gap, equipping companies with the strategic frameworks and technical tools required to manage complex compliance demands. Operations can be supported across three core pillars:

• Regulatory Tracking: Through the TDi Standards and Regulations Tool, data-driven insights support procurement and legal teams. This tracks how voluntary sustainability standards complement due diligence and reporting requirements for current and upcoming regulations, alongside updates concerning evolving 2026 and 2027 deadlines.
• Digital Traceability: Through the TDi Digital Platform, commodity risk screening and deep-tier supplier mapping identify immediate supply chain vulnerabilities. A comprehensive country and commodity risk assessment tool pinpoints risk origins to guide mitigation procedures.
• Systems Implementation: TDi’s expert team supports organisations in building and operationalising the Due Diligence Management Systems (DDMS) required by third-party auditors. Our team can support you with preparation for upcoming second-party and third-party audits, which includes establishing robust policies and internal verification frameworks. Read our case study on development of DDMS: Supporting a major European small electronics company in conducting digital EUBR due diligence

Get ahead of your compliance timelines.

Schedule a consultation with TDi Sustainability to assess your risk exposure and build your EUBR roadmap.

• Regulation (EU) 2023/1542 of the European Parliament and of the Council concerning batteries and waste batteries.
• OECD Due Diligence Guidance for Responsible Supply Chains.
• European Commission Product Environmental Footprint (PEF) guidelines.
• Swappable Batteries Motorcycle Consortium
• Umicore Due Diligence Compliance Report – Cobalt, Lithium and Nickel Procurement – reporting year 2025
• Battery Passport Technical Guidance – March 2024 (reference: 80-100 mandatory data attributes required per battery)