The digital battery passport in Article 77(1) of Regulation (EU) 2023/1542 applies to four categories: EV batteries, LMT batteries, industrial batteries above 2 kWh, and SLI batteries within scope as the provisions apply. Ordinary portable batteries — the cells and packs in phones, laptops, power tools and most consumer electronics — are not covered by the Article 77 passport obligation.
Where the nuance bites for OEMs
The category a battery falls into is decided by definition, not by the device it powers. A portable battery is, broadly, a sealed battery weighing 5 kg or less that is not designed for industrial use and is neither an LMT, EV nor SLI battery. If an OEM ships a larger pack — for example a portable power station, a large energy-storage product, or a battery in a light wheeled vehicle — that pack may meet the industrial (> 2 kWh) or LMT definition and then does require a passport.
| Product | Likely category | Passport |
|---|---|---|
| Phone / laptop battery | Portable | No Article 77 passport |
| Power-tool pack | Portable (typically) | No Article 77 passport |
| Portable power station > 2 kWh | Possibly industrial | Likely required — check definition |
| E-bike / e-scooter pack | LMT | Required from 18 Feb 2027 |
So a consumer-electronics OEM should not assume blanket exemption. The right step is to classify each battery against the regulation definitions (capacity, weight, intended use) and issue passports only for the packs that cross into LMT or industrial territory. Getting the classification wrong in either direction is a compliance risk.
Frequently asked
Are laptop and phone batteries covered by the battery passport?
Generally no. They are portable batteries, which are outside the Article 77 digital passport obligation. Other parts of the regulation, such as labelling and removability, may still apply.
When does a consumer-electronics OEM fall into passport scope?
When a product contains a battery that meets the LMT definition or the industrial (> 2 kWh) definition rather than the portable definition. Classification follows the battery characteristics, not the consumer-product label.