Batteries and charging

EU Declaration of Conformity for E-Bikes, E-Bike Batteries and E-Scooters: requirements and checklist

By Ing. Jaroslav Křepelka, Owner, DoC solutions s.r.o. · Updated 22 September 2026

Pedal-assisted e-bikes (EPACs, up to 250 W and 25 km/h) and stand-up e-scooters are excluded from vehicle type approval, so in the EU they are placed on the market as machinery, with a Declaration of Conformity under the Machinery Directive and, from 20 January 2027, the Machinery Regulation. Their traction batteries are LMT batteries under the Batteries Regulation, which adds a battery passport from February 2027.

This page covers EPACs, replacement e-bike batteries and personal e-scooters. Faster e-bikes (speed pedelecs) and seated scooters are type-approved L-category vehicles and follow a different regime.

Checklist: what your e-bike, e-bike battery / e-scooter declaration must contain

Model exactly as on the frame or deck label, with frame sizes, motor and battery variants covered
Name and postal address of the manufacturer (and of the person authorised to compile the technical file, established in the EU)
Machinery Directive 2006/42/EC until 19 January 2027, Machinery Regulation (EU) 2023/1230 from 20 January 2027
EMC Directive 2014/30/EU and RoHS Directive 2011/65/EU
The harmonised standards applied, such as EN 15194 for EPACs
For a battery sold separately: its own declaration under Regulation (EU) 2023/1542
Place and date of issue, name and function of the signatory, and the signature

Which EU legislation applies

Legislation	Applies?	In the DoC?	Notes
Machinery Directive → Machinery Regulation2006/42/EC → (EU) 2023/1230	Applies	In the DoC: Yes	EPACs with a motor of at most 250 W that cuts out at 25 km/h, and vehicles without a seating position such as stand-up e-scooters, are excluded from type-approval Regulation (EU) No 168/2013 (Article 2(2)), which leaves them within machinery legislation. The Machinery Regulation applies from 20 January 2027.
EMC Directive2014/30/EU	Applies	In the DoC: Yes	Motor controller, display and charging electronics.
RoHS Directive2011/65/EU	Applies	In the DoC: Yes	Electric two-wheel vehicles that are not type-approved are within RoHS scope.
Batteries Regulation(EU) 2023/1542	Applies	In the DoC: Yes	Traction batteries up to 25 kg for such vehicles are LMT batteries. Conformity assessment, CE marking and a declaration apply since 18 August 2024; from 18 February 2027 LMT batteries need a battery passport, and products must allow the battery and its cells to be removed and replaced by an independent professional.
Radio Equipment Directive2014/53/EU	Depends on model	In the DoC: Yes	For bikes or scooters with Bluetooth, GPS tracking or app connectivity. Internet-connected models must also meet Delegated Regulation (EU) 2022/30.
WEEE Directive2012/19/EU	Applies	In the DoC: No	Electric two-wheel vehicles that are not type-approved fall within WEEE scope; producer registration applies, plus battery producer registration.

Typical harmonised standards

A harmonised standard gives presumption of conformity only in the version cited in the Official Journal of the EU. Always check the current list for each directive before you issue or update a declaration (European Commission: harmonised standards); the versions below are the ones commonly used at the time of writing, and the right selection depends on your product.

Machinery

EN 15194:2017 + A1:2023Electrically power assisted cycles (EPAC). Cited with a restriction: it does not cover the vibration requirements (Annex I points 1.5.9 and 3.6.3.1), which must be addressed separately
EN 17128Light motorized vehicles for personal transport (e-scooters). Widely used, but not cited in the Official Journal, so it gives no presumption of conformity
EN ISO 12100:2010Safety of machinery — risk assessment and risk reduction

Battery

EN 50604-1Secondary lithium batteries for light electric vehicle applications — the usual safety standard for e-bike and e-scooter packs

Already have a declaration for your e-bike, e-bike battery / e-scooter?

A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).

Common mistakes in e-bike, e-bike battery / e-scooter declarations

The Low Voltage Directive is cited instead of machinery legislation
An e-bike runs at battery voltage (typically 36–48 V DC), below the LVD range. Its safety is covered by the Machinery Directive; only the mains charger falls under the LVD.
EN 15194 cited as if it covered everything
The Official Journal citation excludes the vibration requirements. The technical file needs its own vibration assessment and the instructions the vibration information.
No transition plan to the Machinery Regulation
E-bikes placed on the market from 20 January 2027 need a declaration referring to Regulation (EU) 2023/1230, with its updated essential requirements.
Battery treated as an accessory
The LMT battery is regulated in its own right: CE marking, declaration, labelling, and from 18 February 2027 a battery passport.
Speed or power limits not enforced
An EPAC that can be easily derestricted, or whose motor exceeds 250 W continuous rated power, is no longer excluded from type approval.

What you need besides the declaration

Technical file: Risk assessment, drawings, test reports against EN 15194 or the chosen standards, vibration assessment, EMC tests, battery safety and transport tests, and RoHS documentation.
Instructions: Machinery instructions in the language of each EU country of sale, including charging, maintenance and vibration information.
Battery transport: A UN 38.3 test summary; e-bike batteries ship as dangerous goods.
Charger: A mains charger is a separate electrical product under the LVD and EMC Directives.
Producer registration: WEEE and battery producer registration in every EU country where you sell.

No EU presence yet? We can act as your EU authorised representative or responsible person.

Frequently asked questions

Is an e-bike covered by the Low Voltage Directive?

No. EPACs are machinery: their battery voltage is below the LVD range. The mains charger is covered by the LVD separately.

What changes for e-bikes on 20 January 2027?

The Machinery Regulation (EU) 2023/1230 replaces the Machinery Directive. Products placed on the market from that date need a declaration under the new regulation.

Is an e-scooter machinery?

Stand-up e-scooters without a seat are excluded from type-approval Regulation (EU) No 168/2013 and are placed on the market as machinery. EN 17128 is the usual product standard but is not harmonised.

What does MyCECheck check on an e-bike declaration?

The machinery legislation and transition date, EN 15194 and its restriction, the battery's own obligations, EMC and RoHS, and whether model and battery variants are identified. Written report within 48 hours.