Portable / OEM

Battery Passport for Consumer Electronics OEMs

Portable consumer-electronics batteries are largely outside the Article 77 passport obligation, but OEMs whose products contain LMT or industrial-class batteries can fall in scope under Regulation (EU) 2023/1542.

Last updated 1 June 2026

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.

ProductLikely categoryPassport
Phone / laptop batteryPortableNo Article 77 passport
Power-tool packPortable (typically)No Article 77 passport
Portable power station > 2 kWhPossibly industrialLikely required — check definition
E-bike / e-scooter packLMTRequired 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.

For the packs in your range that do fall in scope, generate a compliant per-battery passport with the QR code, unique identifier and Annex XIII tiers handled. Per-passport pricing means you only pay for the batteries that actually need a passport. No sales call.

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.

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Self-serve, no sales call. Compliant by 18 February 2027.