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 across battery supply chains, ranging from carbon footprint declarations and Digital Battery Passports to mandatory due diligence for the sourcing of cobalt, natural graphite, lithium and nickel. For e-bike and e-scooter OEMs, understanding how these requirements apply to their batteries, suppliers and own operations is becoming an increasingly important part of regulatory readiness.

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, their EUBR compliance roadmaps can diverge significantly. Specific reporting deadlines and design requirements, such as mandates for battery removability, depend on the classification of the battery and the role of the economic operator placing it on the market.
Electric two-wheelers fall into two primary categories: Electric Vehicles (EVs) and Light Means of Transport (LMTs).

High-Power Electric Vehicles (EVs)
Large electric motorcycles will generally fall within the EV battery definition where their traction battery weighs more than 25 kg. The classification must be assessed against the battery and vehicle characteristics of the individual model. 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. The nominal deadline for carbon footprint declarations was 18 February 2025, but the obligation applies only from the later of that date or 12 months after the relevant Commission delegated and implementing acts enter into force.

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. The classification is determined by the battery’s legal definition – including its weight, whether it is sealed, and the type of vehicle it is designed to power – rather than by the vehicle’s 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: Under the EU Battery Regulation, an EV battery is a battery specifically designed to provide traction to a hybrid or electric L-category vehicle where the battery weighs more than 25 kg, or to a hybrid or electric vehicle in categories M, N or O.

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. The European Commission has issued guidance explaining what is meant by an ‘independent professional’.

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. Misclassifying an LMT battery as an EV battery, or vice versa, can lead to the wrong requirements and deadlines being applied – for example, overlooking the February 2027 replaceability requirement that applies 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 is the initial step for OEMs, followed by aligning product design, battery specifications, supply-chain processes and data systems with the requirements that apply to each battery category and economic-operator role.

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 applicable requirements – including carbon footprint, battery passport and replaceability – are not subject to this specific EUBR due-diligence exemption and apply according to the relevant battery category and economic operator role.

**Carbon footprint timing: The dates above are those specified in Article 7 of Regulation (EU) 2023/1542. The applicable timing varies by requirement and battery category. For the carbon-footprint declaration, the EV-battery requirement applies from 18 February 2025 or 12 months after the relevant delegated or implementing act enters into force, whichever is later; for LMT batteries, the corresponding period is 18 months after those acts enter into force. The carbon-footprint performance-class requirements for both EV and LMT batteries use an 18-month period. The maximum life-cycle carbon-footprint thresholds also use an 18-month period after the relevant delegated act enters into force.

For e-bike and e-scooter OEMs, navigating EUBR requirements – from carbon-footprint declarations and Digital Battery Passports to supply-chain due diligence – requires a level of battery data, supplier visibility and internal coordination that many organisations are still developing.

TDi Sustainability helps e-bike and e-scooter OEMs bridge that gap, providing the strategic frameworks and technical tools needed to understand regulatory exposure, strengthen supply-chain visibility and prepare for complex EUBR compliance requirements. 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 EUBR readiness, identify supply-chain and data gaps, and build a practical compliance roadmap.

Download our information document on the 7 pillars of EUBR compliance.

• 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)