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Adaptr
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Industrial and storage · Reviewed 30 September 2026

Industrial batteries are in scope above 2 kWh.

This is the only category the capacity threshold applies to. Forklift packs, stationary storage and large UPS systems are in or out depending on their energy, and the figure is easy to be wrong about in both directions.

18 Feb 2027Above 2 kWh for industrial and storage

How the threshold works

Article 77 puts industrial batteries with capacity greater than 2 kWh in scope from 18 Feb 2027. It is a threshold on this category only — EV and LMT batteries are in scope by category, with no size test, so a figure carried across from here gets those two wrong.

Energy, not amp-hours. A pack is measured in kWh, which means rated capacity and nominal voltage together — a capacity figure alone does not answer the question.

Source: Regulation (EU) 2023/1542, consolidated text

When capacity is not recorded

A pack whose rated capacity nobody has recorded cannot be shown to be under the threshold. Adaptr treats that pack as in scope until the figure exists, which is the cautious direction: the alternative is a fleet quietly excluding the batteries it knows least about.

In practice this is the most common finding on a first look at a real fleet — not packs that are out of scope, but packs nobody can place either way.

Knowing which of yours are in scope

Scope is decided per pack, from its category and its energy. For a mixed estate — forklifts, storage, standby — that is a question about the records you hold rather than about the regulation, and it is answerable today without waiting for the deadline.

Adaptr derives the answer from the pack’s category and rated capacity rather than storing a flag, so a battery that is recategorised or has its capacity corrected is reassessed rather than left with a stale verdict.

Where to read next

What a battery passport must contain · What the deadline requires · Great Britain, Northern Ireland and EU supply

Other categories: EV traction batteries · LMT batteries — e-bikes and e-scooters

A practical first step

Find out how many of yours you cannot place.

Bring a list of packs and what you hold about them. We will show you which are in scope, which are out, and which nobody can say.

Request a demo