Counterfeit e-bike batteries, and what a passport can prove
Start with the number nobody has: no UK or EU authority publishes a count of fires caused by counterfeit battery packs. The word does not appear in the Battery Regulation, and the EU Safety Gate alert database has no counterfeit category to filter on.
What the published data does separate is packs built by the manufacturer from packs that arrived afterwards — and that line is where the fires sit. This page sets out what is actually measured, what a battery passport proves about an individual pack, and the two narrow things a tamper-evident tag can tell you. Everything here carries the scope its publisher gave it.
- Fires caused by counterfeit packs
- No published figure, any jurisdiction
- “counterfeit” in Reg. 2023/1542
- Does not appear
- Counterfeit category in Safety Gate
- Does not exist
- UK e-bike fires notified, 2024
- 170, of which 45% conversions
- Passports linked to fire outcomes
- No study, either way
The regulation never uses the word counterfeit
It is the word buyers search for, and it is not a legal category. Knowing what the law does say instead is the difference between buying a control and buying a slogan.
Regulation (EU) 2023/1542 works through conformity, not authenticity. A pack is lawful or it is not, and market surveillance authorities enforce that distinction: a battery that fails any relevant requirement is a non-compliant battery, and they must require corrective action, withdrawal or recall, Article 79. Nothing in the text asks whether the pack is a fake of somebody else’s product.
The same gap shows in the enforcement data. The EU Safety Gate database, where national authorities publish weekly measures against dangerous non-food products, records a risk type and a measure — not whether an item was counterfeit. So even where a fake pack is taken off the market, the record that survives describes the hazard, not the deception.
This matters commercially. A supplier selling you protection against counterfeiting is selling something the regulation does not require and does not define, which is fine — as long as the claim is about what the control actually does. Ours is set out below, including what it cannot do.
The documented problem is packs outside the manufacturer’s chain
Two UK sources are specific enough to quote, and both point the same way. Neither is a European incidence rate, and neither publisher claims it is.
| Figure | Exact scope | Source |
|---|---|---|
| 45% of 170 | E-bike fires occurring in 2024 and voluntarily notified to the UK Office for Product Safety and Standards, confirmed as post-market conversions to electric. A further 59 were unknown build, so 45% is a floor, not a share of all e-bike fires. | OPSS, 2024 edition |
| Over three quarters | Of the 56% of London Fire Brigade e-bike fire incidents between 2017 and 2023 where the build could be ascertained, the share that involved conversion kits rather than manufacturer-built e-bikes. | WMG for OPSS, 29 Jan 2025 |
| 93% of 211 | E-bike and e-scooter fires notified to OPSS for 2024 recorded with batteries or generators as the source of ignition. Batteries or generators, not batteries alone. | OPSS, 2024 edition |
| 211 fires | Total notified to OPSS for 2024, of which 175 came from a single brigade, London. OPSS states the data cannot be used to estimate incidents at a national level, and that comparisons across years should be made with care because the reporting base grew. | OPSS, 2024 edition |
One sentence from London Fire Brigade, reporting a record year in January 2026, is worth more than the counts: “each of the five people who have died in fires in London did not own the e-bike involved”. Battery safety is not only a risk to the buyer, and that is the argument for identification that survives every caveat above.
A tap proves two narrow things, and not a third
We sell the tamper-evident tag, so this is the section where a vendor is most tempted to overstate. Here is the boundary, with the closest thing the law has to a precedent.
- It proves
- A genuine, individually keyed chip answered this tap.
- It proves
- Whether the seal has been broken since the label was applied.
- It does not prove
- That the chip is still on the battery it was issued for.
- It does not prove
- Anything about the cells inside the case.
A printed code can be copied. GS1’s own guidance on digital signatures says it plainly: a product barcode, even at serial level, could simply be copied and reprinted onto counterfeit goods, and it recommends pairing signed data with a physical security marking. That is the whole argument for a chip over a print, and it is the whole of it.
The nearest legal precedent is not in battery law at all. For falsified medicines, the Commission splits the job in two: the unique identifier exists to show the product comes from the legitimate manufacturer, while the anti-tampering device shows whether the packaging has been opened or altered since it left that manufacturer. Neither answers whether the contents match the record. The same split applies here, and pretending otherwise would be the easiest lie on this page.
Detecting a cloned identity is a different job again, and the tag does not do it alone: it takes scan records showing the same identifier answering in two places. And note what the law actually requires, which is less than what we sell. Article 13(6) mandates a QR code; Article 77(3) mandates a unique identifier compliant with the ISO/IEC 15459 series. NFC is not the statutory carrier. It is a stronger one, chosen because a printed code cannot verify anything about the object carrying it.
A Union-wide recall is bounded by the data you can produce
This is where identification stops being paperwork. The duty is wide; the reach of the duty is exactly as wide as your records.
Corrective action must cover all the non-compliant batteries the operator has made available on the market throughout the Union, not only those in the country that found the problem: Article 79(3).
What goes to the authorities includes the data necessary for the identification of the non-compliant battery and its origin: Article 79(5). No identification, no defensible scope.
Under the General Product Safety Regulation, a recall notice has to reach all affected consumers that can be identified: Article 35(1) of Regulation (EU) 2023/988.
Article 46(2) asks operators to identify who supplied them and who they supplied, for 10 years each way. Companies, not units. The passport identifier is what closes that gap.
Read together, these turn identification into the variable that decides what a recall costs. A batch you can name is a batch you withdraw; a batch you cannot is a market-wide notice, and the packs that will not carry a passport at all — conversions, grey imports, mix-and-match kits — are the ones no record will help you find. Enforcement will meet them the hard way.
The passport follows the pack into its second life
The record is not a birth certificate filed once. It changes hands, it gains data from the field, and it ends.
State of health is not public. Annex XIII splits the passport into four parts by who may read them, and the data relating to an individual battery — the performance and durability values that make up state of health, drawn from Article 10(1), which has applied to LMT batteries since 18 August 2024 — sits in the part reserved to persons with a legitimate interest. Who qualifies was left to a Commission implementing act due by 18 August 2026, and at the time of writing it has not been adopted. Anyone selling you certainty about those access rules today is ahead of the Commission.
A refurbished pack does not inherit its old record. A battery prepared for re-use, repurposed or remanufactured must have a new battery passport linked to the original’s, and the obligations transfer to whoever places it on the market: Article 77(7). That link is the audit trail a second-life operator works from, and it is why a repurposed pack can still be traced to the cells it was built out of. When the battery is finally decommissioned and recycled, the passport ceases to exist, Article 77(8) — so the record has to be retained and reachable for the whole service life in between, not for a fixed number of years.
One clarification worth making, because the names collide: the Global Battery Alliance runs a battery passport of its own, and it states that it is not formally affiliated with the European Commission. It is a voluntary sustainability scheme. The passport that becomes compulsory on 18 February 2027 is the one in Article 77, and the two should never be quoted as the same obligation.
The questions a safety manager asks first
Short answers with the article or the source attached, because on a safety question the source is most of the answer.
Can a battery passport tell me if a battery is counterfeit?
Not on its own. The passport is reached through a QR code linked to a unique identifier, Article 77(3), and a printed code can be photographed and reprinted onto another pack. GS1's own guidance on digital signatures makes the same point about serialised barcodes. What raises the bar is binding the record to something that cannot be reprinted, such as an individually keyed chip, and even then the honest claim is narrow: the chip answered, and the seal was intact or it was not.
How many e-bike fires are caused by counterfeit batteries?
Nobody has published that number, in any jurisdiction we could find. The Regulation does not use the word counterfeit and the EU Safety Gate database has no counterfeit category. What the published data does quantify is a different distinction: packs built by the manufacturer versus packs that arrived afterwards. In the UK, 45% of the 170 e-bike fires notified to the product-safety regulator for 2024 were confirmed post-market conversions.
Does a battery passport make an e-bike battery safer?
No. A passport is a record, not a protection: it does not change what is inside the pack, and an authentic pack can still catch fire. Cell safety comes from design, testing and conformity assessment. What the passport changes is what happens after something goes wrong, because a recall can only reach the batteries somebody can identify.
Who has to be able to trace a battery, and for how long?
Every economic operator must be able to say who supplied them a battery and who they supplied it to, for 10 years in each direction: Article 46(2). That is one step up and one step down the chain, and it identifies companies rather than individual packs. The passport is what adds an identifier to the individual battery, and it must stay reachable until that battery is recycled, Article 77(8).
What happens to the passport when a pack is refurbished?
It does not carry over. A battery prepared for re-use, repurposed or remanufactured gets a new battery passport linked to the passport of the original, and responsibility moves to whoever places the repurposed battery on the market: Article 77(7). That link is what lets a second-life pack be traced back to the cells it came from.
Three passports, three verdicts, one of them tampered
The clearest way to judge any of this is to scan the live records yourself. One verifies, one flags an opened tamper loop, one says authenticity cannot be verified — the same server-side answer a customer of ours would get.
Sources, all read on 27 August 2026: Regulation (EU) 2023/1542, consolidated text of 31 July 2025 (Arts. 10, 13, 46, 77–79, Annex XIII); Regulation (EU) 2023/988 on general product safety; OPSS, fires in e-bikes and e-scooters 2024 (voluntary notifications, UK, not a national incidence estimate); PLEV battery safety research for OPSS (WMG, London Fire Brigade incidents 2017–2023, published 29 January 2025); London Fire Brigade, January 2026; EU Safety Gate; GS1 guideline on digital signatures; Commission Delegated Regulation (EU) 2016/161 on safety features for medicinal products; Global Battery Alliance. Figures are quoted with the scope their publishers state, and no figure has been converted, combined across sources, or presented as a trend.