Replaceability of LMT batteries
Article 11 of the Batteries Regulation applies from 18 February 2027. In products with a battery for light means of transport (LMT), such as e-bikes and electric kick scooters, an independent professional must be able to remove and replace the battery easily. That also applies to the individual battery cells in the battery pack (Article 11(5)). The obligation lies with the party that places the product on the market.
There is a proposal in Brussels to relax the requirement from individual cells to modules. The Council supports that. The eighteen-month postponement the Council also wants applies to certain products with portable batteries, not to e-bikes and electric kick scooters. It has not yet been adopted. Until then, 18 February 2027 applies.
Battery passport from 18 February 2027
From 18 February 2027, LMT batteries, industrial batteries with a capacity above 2 kWh and EV batteries that are placed on the market or put into service must have an electronic battery passport. The passport contains information about the model and, depending on access rights, about the individual battery and its use.
What does this mean for manufacturers and importers?
Aftersales, spare parts, replaceability, technical information and traceability become more important. KWS can carry out the technical service side: diagnosis, repair criteria, repair, final test, return and the data we agree on.
We do not take over the legal role and product responsibility of the manufacturer or importer. Read how that works under warranty and aftersales and on the page for manufacturers and importers.
What does this mean for dealers and service companies?
Dealers are increasingly asked which battery can technically be repaired, which information belongs with a service case and what a safe return process looks like. A clear process between dealer, technical specialist and manufacturer becomes more important as a result.
Repair, cell replacement and remanufacturing are not the same
KWS uses the words repair, cell replacement and refurbished for its services. Remanufacturing is something else: the Batteries Regulation defines it legally and attaches technical and conformity obligations to it.
Anyone who rebuilds a battery to comparable specifications therefore cannot assume, without an assessment, that the original markings and the conformity status still apply.
Right to Repair
Directive (EU) 2024/1799 on promoting the repair of goods obliges manufacturers to repair certain products at the consumer's request, including after the warranty. Products with an LMT battery are covered, in so far as the repairability requirements of Article 11 apply.
So it is not a general obligation that every battery must be repairable by every repairer. What the directive asks of manufacturers and importers is explained on our page about Right to Repair.
Each member state transposes the directive into national law. In the Netherlands that still has to happen: the bill is before the House of Representatives.
Frequently asked questions
LMT batteries that are placed on the market or put into service from 18 February 2027 fall under the passport obligation. A battery that returns to the market after preparation for re-use, repurposing or remanufacturing gets a new passport (Article 77(7)). How that works out for a specific product or a specific market role has to be assessed case by case.
For LMT batteries, Article 11 contains requirements from 18 February 2027 for removability and replaceability by an independent professional. Those requirements also apply to the individual cells in the battery pack. The Commission's non-binding guidelines (C/2025/214) explain how this works in practice, including the compatibility and safety of replacement cells.
That cannot be answered with a general yes or no. The legal role depends on the nature of the change, the product and the conformity rules that apply to it. That is why we assess remanufacturing and larger product changes case by case.
No. KWS supports the technical battery service and the design of the process. Formal product compliance, the roles of economic operators and legal responsibility are a separate field of expertise.
Sources
- Regulation (EU) 2023/1542 (Batteries Regulation), in particular Article 11 and Article 77.
- Directive (EU) 2024/1799 on promoting the repair of goods.
- Proposal COM(2025) 981 (environmental omnibus), still under consideration.
Content last checked: October 2026.
Want to know what this means for your battery process?
We look at the technical side with you: service, returns and the data you need to be able to show. You can also read about quality and safety, PGS 37-2 and knowledge and advice.