The short answer
2 kWh decides whether an industrial battery needs a battery passport; 5 kg and 25 kg decide which type a battery is. The regulation says “greater than”: an industrial battery needs a passport only above 2 kWh, not at exactly 2 kWh. An LMT battery weighs 25 kg or less, an L-category vehicle traction battery above 25 kg is an electric vehicle battery, and a portable battery weighs 5 kg or less.
What the regulation says
2 kWh: does an industrial battery need a passport
“From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).”
5 kg: portable batteries
“‘portable battery’ means a battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is neither an electric vehicle battery, an LMT battery, nor an SLI battery;”
5 kg: industrial batteries
“‘industrial battery’ means a battery that is specifically designed for industrial uses, intended for industrial uses after having been subject to preparation for repurposing or repurposing, or any other battery that weighs more than 5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery;”
25 kg: LMT batteries
“‘light means of transport battery’ or ‘LMT battery’ means a battery that is sealed, weighs 25 kg or less and is specifically designed to provide electric power for the traction of wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, including type-approved vehicles of category L within the meaning of Regulation (EU) No 168/2013 of the European Parliament and of the Council, and that is not an electric vehicle battery;”
25 kg: electric vehicle batteries
“‘electric vehicle battery’ means a battery that is specifically designed to provide electric power for traction in hybrid or electric vehicles of category L as provided for in Regulation (EU) No 168/2013, that weighs more than 25 kg, or a battery that is specifically designed to provide electric power for traction in hybrid or electric vehicles of categories M, N or O as provided for in Regulation (EU) 2018/858;”
Quotes are from the English text of the regulations; the text published in the Official Journal prevails.
What each threshold decides
| Threshold | What it decides | How it is counted |
|---|---|---|
| 2 kWh | Whether an industrial battery needs a battery passport | A passport is needed above 2 kWh. At exactly 2 kWh or less there is no passport, but the battery carries a QR code. The regulation only says "a capacity greater than 2 kWh" and does not say how to calculate it; it is generally read as the rated energy the manufacturer declares (rated capacity in Ah × nominal voltage in V ÷ 1000). It is counted on the “finished battery”: the battery that works on its own and safely as placed on the market (Commission FAQ 3.1). Several packs that share a battery management system (BMS) or other common parts and only work together are one battery, and their combined capacity counts; packs that each work on their own are judged one by one (FAQ 3.2, 3.3). This is decided case by case. The FAQ says nothing on capacity limited by software, so ask a professional for that. |
| 5 kg | Whether a battery is a portable or an industrial battery | A sealed battery of 5 kg or less that is not designed for industrial use is generally portable. A battery above 5 kg that is not an electric vehicle, LMT or starting battery is industrial. |
| 25 kg | Whether a battery is an LMT or an electric vehicle battery (category L vehicles) | 25 kg or less is an LMT battery, above 25 kg an electric vehicle battery. Both need a battery passport. |
Home storage is industrial at any weight; see Does my battery need a battery passport?.
Common mistakes
Does a battery of exactly 2 kWh need a passport?
No. The regulation says “greater than 2 kWh”. An industrial battery of exactly 2 kWh or less needs no passport, but carries a QR code from the same day.
Is every outdoor power station a portable battery?
Not always. One above 5 kg is generally treated as an industrial battery, and above 2 kWh it needs a passport. One of 5 kg or less is generally portable. The regulation does not say whether an outdoor power station is stationary storage; ask a professional if you are unsure.
Does a heavier L-category vehicle battery escape the passport?
No. An L-category traction battery above 25 kg is an electric vehicle battery and needs a passport. At exactly 25 kg it is still an LMT battery, which needs one too.
Update dates and checks
- First published
- Last updated
- Checked against
- Regulation (EU) 2023/1542 (Battery Regulation), consolidated text; Commission battery passport FAQ (completed September 2026, 1st edition, not law)
- Checked
- Checked 2026-11-07 · by PassBridge
This guide is for reference and is not legal advice. When the rules change we update it and say so here.
