regulation
We're an E-Bike Brand and Our Supplier Builds the Packs — Whose Job Is the Battery Passport?
For LMT brands that outsource pack assembly, the passport obligation usually lands on the brand, not the assembler. Here's the rebadging trap and how to close the data gap it creates.
The short answer
If the pack goes to market under your brand, the passport is your job — even though you never touched a cell. LMT batteries (e-bikes, e-scooters, Class L vehicles) are in the first passport wave from 18 February 2027, and the obligation binds the economic operator placing the battery on the EU market. For the standard outsourced model — brand designs the vehicle, contract assembler builds the pack — that operator is usually the brand.
Many LMT brands discover this late, because it feels backwards: the assembler owns the genealogy, so surely they own the passport? They own the data. You own the obligation.
The rebadging trap, structurally
The typical outsourced-pack brand runs a storefront, a light ERP for inventory and purchase orders, and a PIM for the customer-facing product story — specs, range claims, images. Supplier documentation (the pack maker's certificates, the cell datasheet) lives in PDFs and a spreadsheet. Critically, the ERP and the supplier compliance data have zero integration: when a pack's compliance evidence is needed, someone assembles it by hand from emails.
That structure worked when compliance meant producing a certificate on request. It fails against a passport, which demands structured, per-model and per-unit data — because the passport is only as good as the supplier file you can extract, and a confident-looking passport resting on a supplier relationship that can't deliver cell genealogy on demand is a liability with a QR code on it.
Why your PIM can't save you
Brands sometimes assume their product-data systems already hold what's needed. They hold half. The PIM is the marketing record — range, weight, warranty, the spec sheet. The engineering record — BOM, cell provenance, BMS firmware, test genealogy — lives in the assembler's systems, at a different company. The passport needs both halves, and no export from your side alone will ever contain the assembler's half. The work is contractual before it is technical.
Closing the gap
- Confirm operator status per channel. Direct sales, EU distributors, marketplace sales — who places each battery on the market? Don't assume; check.
- Make passport data a contractual deliverable with a field-list annex: chemistry, origins, due-diligence references, carbon footprint contribution, genealogy at the depth the passport needs. Renewal negotiations are your leverage.
- Test the supplier now with one real request. Ask for the complete dataset for one current pack model. The response time and quality is your single best readiness indicator.
- Structure what arrives. Data delivered as PDFs re-creates the manual-assembly problem. Require machine-readable delivery — a spreadsheet with agreed columns beats a beautiful PDF.
What this means for your team
Your passport program is a supplier-management program wearing a compliance badge. Start the contractual clock this quarter — an assembler who can't deliver the annex in 2026 won't magically deliver it under deadline pressure in early 2027, and switching pack suppliers takes longer than building any software ever will.