Battery models & application classes.
EU Regulation 2023/1542 distinguishes five categories - with very different obligations. Which drawer you fall into decides passport duty, carbon declaration and recycling quotas.
- LMT, industrial (> 2 kWh) and EV batteries need a passport from 18 Feb 2027. Portable and SLI do not.
- BESS belongs to the "industrial" category - even when people colloquially speak of home storage.
- The 2 kWh threshold refers to rated energy, not to peak power.
- A modular system of several packs counts as one battery if the manufacturer markets it as a unit.
How the regulation sorts things
Which obligations hit you almost never depends on "what you build", but on "which category it falls into by EU definition". That's exactly why it pays to look at the thresholds.
When it gets complicated in practice
Home storage below 2 kWh: In theory no passport duty. In practice almost non-existent - nearly all home BESS start at 3–5 kWh and are therefore fully subject to the passport.
Swappable pack for several devices: A 36 V swap pack for garden tools is portable; the same pack in an e-cargo bike is LMT. What matters is the placing on the market, not the later use.
Mobile working machines (excavators, aerial platforms): Fall under industrial, not EV - a different conformity regime, different recycling quotas.
Hybrids of several chemistries: If a home storage mixes LFP modules and an old NMC module, the passport applies the dominant chemistry by energy share - secondary chemistries are declared additionally.
The four market archetypes
Behind the five categories stand four very different market realities. We have a dedicated profile for each.
Do I need a passport - or not?
The short answer: If you manufacture, import or sell LMT, industrial (> 2 kWh) or EV batteries under your own name - yes. If you only place portable devices (tools, smartphones, toys) or classic SLI starter batteries on the market - no, but other obligations (recycling, labelling, end-user information) still apply.
The longer answer depends on your specific product portfolio. That's exactly what we built a free eligibility check for: three minutes, no sign-up, a clear result.
90 seconds to passport clarity.
Three minutes of the eligibility check show you exactly which models in your portfolio need a passport by 2027 - and which fields come first.