E-WILDX BUYER WORKSHEET — EU LMT BATTERY PASSPORT READINESS
For e-bike and e-scooter importers, distributors and suppliers
Review date: 21 October 2026

Use this worksheet to prepare a supplier discussion for a battery placed on the European Union market. It is an inquiry and evidence tracker, not legal advice, a conformity assessment, or a determination that a particular vehicle or battery is an LMT battery.

WHY THIS IS ON THE BUYING CHECKLIST
Regulation (EU) 2023/1542, Article 77, provides that from 18 February 2027 each LMT battery placed on the market or put into service must have an electronic Battery Passport. The European Commission identifies batteries for e-bikes and e-scooters among the affected categories. Confirm the legal category of the exact finished battery, the relevant market operator and current requirements with qualified EU compliance counsel or the competent authority.

The Commission's August 2026 data-point guidance distinguishes mandatory, optional, conditional and not-yet-applicable fields. The Commission FAQ clarifies that not all fields apply to every battery, and that carbon-footprint, recycled-content and due-diligence information are not required at the February 2027 start date. Read current guidance with the Regulation and check for later updates.

BUYER / ORDER
Company and contact:
EU destination market(s):
Importer / distributor / other role under review:
Product model and quoted revision:
Supplier and quotation / purchase-order reference:
Expected first EU market placement or put-into-service date:

IDENTIFY THE FINISHED BATTERY
Battery manufacturer and economic operator named for the finished battery:
Battery model / type / pack identifier:
Battery configuration and nominal ratings as quoted:
Does the pack operate as an independent finished battery, or form one system with other packs / shared BMS? Supplier explanation:
Vehicle model / revision and battery-to-vehicle mapping:
LMT category and applicability confirmed by (adviser / authority / date):
Battery passport required for this exact battery and date? (confirmed / not applicable / unresolved):

SUPPLIER DATA AND EVIDENCE REQUEST
Ask the supplier to map the exact battery model and applicable individual-battery data to the Commission's current category-specific guidance. For each field, record the source evidence, responsible data owner and whether the field is mandatory, optional, conditional or not applicable at the relevant date.

Data-point map / guidance version and date:
Battery-model information source records and responsible party:
Individual battery identifier / serialisation approach:
Battery-to-vehicle and production-lot traceability:
Applicable markings and QR-code plan:
Passport creation / hosting / access approach:
Data update, repair, replacement and status-change workflow:
Data corrections and record-retention contact:
Open fields and evidence still required:

RESPONSIBILITY AND WRITTEN ARRANGEMENTS
Economic operator placing the finished battery on the EU market (to be confirmed for the transaction):
Who will create the passport data:
Registry registration in the EU DPP Registry must be completed by the economic operator that places the battery on the EU market. Record that operator and how it will complete registration:
Who will create or update passport data (may be a written delegate):
Who will maintain the record and provide access:
If a supplier or service provider acts for the responsible operator, written authorization / mandate reference:
Contract clause or other written agreement covering accurate and timely data, evidence, changes, access, updates and support:
Separate data work from Registry registration: a manufacturer, supplier or service provider may be authorized in writing to create or update passport data, but the economic operator placing the battery on the EU market must register the passport in the DPP Registry. Written delegation does not transfer that operator’s ultimate responsibility. The Registry became operational on 20 July 2026; use the official test environment and user guide to review the workflow. The Commission helpdesk supports technical onboarding and Registry functionality, not policy interpretation. Confirm role allocation against current guidance and professional advice.

REGISTRY IMPLEMENTATION, PASSPORT HOSTING AND DATA ACCESS
Commission Implementing Regulation (EU) 2026/1778, published 17 July 2026, sets implementation arrangements for the DPP Registry. The Commission FAQ distinguishes that Registry from the full Battery Passport: the Registry records registration information and metadata, while the responsible economic operator or its authorized provider hosts the Passport and manages access. Do not assume Registry registration means the Registry stores or serves every underlying battery data field.

For the exact transaction, record:
- DPP Registry registration operator and the evidence/confirmation it will retain.
- Passport data host, written delegation if used, access management, correction/update workflow and continuity arrangements if the provider changes.
- Which data is public, restricted or accessible only under defined conditions, based on the current applicable rules.
- Contract terms for data accuracy, availability, security, correction, export/transfer and service termination.

The Commission Battery Passport FAQ (manuscript completed September 2026) says the implementing act defining access to restricted Battery Passport data was still under development and expected in draft form for feedback in October or November 2026. Check the current official status before relying on access assumptions or finalizing data-sharing terms. The implementing regulation for Registry operations does not itself settle those Battery Passport access rights. This checklist does not interpret the law or confirm a supplier’s technical capability.

Official references:
Commission Implementing Regulation (EU) 2026/1778: https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng
Commission DPP Registry overview: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/dpp-registry_en
Commission Battery Passport FAQ, especially sections 1.4, 2 and 6: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en

READINESS REVIEW
Current Commission guidance and Regulation checked on:
Product/battery classification and responsible operator reviewed by:
Missing data, documents or system capabilities:
Required actions, owner and target date:
Readiness status (not started / gathering evidence / unresolved / reviewed):
Buyer decision and date:

OFFICIAL REFERENCES
Regulation (EU) 2023/1542, especially Articles 13 and 77 and Annex XIII:
https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

European Commission, Digital Product Passport for Batteries:
https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en

European Commission, Battery Passport FAQ:
https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en

European Commission, DPP Registry user guide for economic operators (published 16 September 2026):
https://single-market-economy.ec.europa.eu/document/download/079a45e2-469f-4eec-b1e5-32e8e05d1357_en?filename=dpp_registry_user_guide_for_economic_operators.pdf

European Commission, Registry test environment:
https://registry.acc.product-passport.ec.europa.eu/

European Commission, August 2026 data-point guidance announcement:
https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en

This worksheet does not confirm whether any e-wildx model, battery, supplier or order is ready for EU market placement. Verify the current legal text, guidance and national obligations for the exact transaction.


EU BATTERY PRODUCER REGISTRATION AND EXTENDED PRODUCER RESPONSIBILITY (EPR)
This is a separate workstream from product conformity and the Digital Battery Passport. Regulation (EU) 2023/1542 Articles 55–56 require producer registration in each Member State where the producer first makes a battery available and address EPR for batteries, including batteries incorporated into light means of transport or other vehicles. The entity that qualifies as the producer depends on the transaction and the applicable legal definitions. Do not infer the responsible battery EPR entity solely from who is called the vehicle importer.

For each intended destination market, record and confirm with the competent authority or a qualified adviser:
- Exact finished battery model, category and chemistry; whether incorporated in the vehicle or supplied separately.
- Entity and transaction route under which the battery is first made available in that Member State; responsible producer determination and evidence.
- Applicable national producer register, registration number/status and effective date.
- Individual or collective compliance route, appointed producer-responsibility organisation (if used), its mandate and service scope.
- Applicable EPR fee basis, sales-volume reporting, collection and end-of-life arrangements, records and reporting timetable.
- Any current national representative or other procedural requirement; verify the law and competent-authority guidance in force for the exact entity and sales channel.

Do not treat this registration as the Digital Battery Passport Registry registration. The passport and battery-waste producer register have different legal purposes and responsible-party analyses. This buyer checklist does not decide which party is legally the producer, calculate fees, register a company, or replace national legal advice. Regulation and national implementation can change; verify before placing products on each market.

Primary reference: Regulation (EU) 2023/1542, especially Articles 3, 55, 56, 57 and 75: https://eur-lex.europa.eu/eli/reg/2023/1542/2026-08-13/eng/


EU BATTERY REMOVABILITY, REPLACEMENT AND SPARE-PART READINESS (ARTICLE 11)
Review the exact finished battery category and the date the product will be placed on the EU market. Article 11 of Regulation (EU) 2023/1542 applies from 18 February 2027 to products incorporating relevant portable batteries and to LMT batteries. A vehicle name alone does not determine the battery category or pathway. The European Commission’s 14 July 2026 guidelines are non-binding implementation guidance.

For the exact battery, vehicle model and revision, ask the supplier to document:
- Battery identity, configuration, category (portable / LMT / unresolved), classification basis and adviser or authority review date.
- Safe removal and replacement steps, including who may perform them and the competence or qualification required for any independent professional.
- Required specialist tools, fasteners, technical instructions and service access, including any applicable LMT cell-level requirements under the current law.
- Compatible replacement battery and, where relevant, cell availability; safety, intended operation, type-approval implications and required validation evidence.
- Diagnostic, firmware or software conditions and confirmation that software does not prevent replacement by a compatible battery where Article 11 requires it.
- Applicable spare-part supply period and price. Article 11(7) provides for portable and LMT batteries to be available as spare parts for at least five years after the last unit of the equipment model is placed on the market, at a reasonable and non-discriminatory price, subject to the provision’s scope and timing.
- Written service, warranty, commercial-use and parts-ordering terms for the destination and sales channel.

Record supplier evidence, unresolved issues, owner and date. Confirm the exact category, exemptions, market-placement date and current requirements with the competent authority or qualified EU adviser. This checklist does not determine legal applicability or claim that an e-wildx product complies.

European Commission guidelines (14 July 2026): https://environment.ec.europa.eu/publications/guidelines-facilitate-harmonised-application-provisions-removability-and-replaceability-portable-and_en
Regulation (EU) 2023/1542, Article 11: https://eur-lex.europa.eu/eli/reg/2023/1542/2026-08-13/eng/