US market · micromobility battery certification · position as at 10 November 2026
What you must prove, and to whom, before you sell an e-bike pack in the United States
There is no federal micromobility battery rule and no US battery passport. Market access is a patchwork of five jurisdictions in force, one proposed federal standard, and retailer conditions. This map sets out, per jurisdiction, which standard must be met, who carries the duty, what must appear on the product or listing, what records you must be able to produce, and what the penalty is.
Certified batteries only; sale and delivery of uncertified packs prohibited
Seller, deliverer
Board vote 23 Jun 2026
Federal (CPSC)
proposed
UL 2849-20 + CPSC additions
UL 2271-23 + CPSC additions
Manufacturer, importer, retailer
180 days after a final rule
verified against the statute or adopted textsecondary source — confirm before quoting
The five jurisdictions in detail
New York City in forceNYC Admin. Code § 20-610
Local Law 39 of 2023, effective 16 September 2023 · amended by Local Laws 49 and 50 of 2024
CertificationE-bikes must be certified by an accredited testing laboratory to UL 2849; other powered mobility devices to UL 2272; storage batteries to UL 2271. A certified battery alone does not satisfy the e-bike requirement.
Who is liableAnyone who sells, leases or rents — including online sellers. Resale of a used device is covered; a device already in use is not.
Must appearThe certification, or the laboratory's logo, wordmark or name, on packaging or documentation at the time of sale, or directly on the device or battery. Online listings must display the certification or the laboratory's identity on the product page.
RecordsRetailers must keep records per device (Local Law 50 of 2024).
PostingFire-safety disclosure sign, in store and online (Local Law 49 of 2024), or civil penalties of $150 / $250 / $350 for first, second, third and later violations.
PenaltyFirst violation: $0 by statute. Each later violation on a different day within two years: up to $2,000 per device type. Failure to display certification on an online listing: up to $500. Each SKU is a separate violation. Repeat violators can be padlocked; FDNY has concurrent enforcement authority.
Enforcement is not theoretical: DCWP reported more than 650 inspections and 275 violations within the first year. The $0 first penalty is a trap, not a free pass — it resets the clock on a two-year lookback, so the second inspection is the expensive one.
New York State in forceGen. Bus. Law § 495-a
S.154F / A.4938-D, Chapter 195 of the Laws of 2024 · effective 9 October 2024
CertificationNo person may manufacture, distribute, assemble, recondition, sell, offer, lease or rent a lithium-ion or second-use battery for an e-bike unless certified by an accredited laboratory to UL 2849, UL 2271 or EN 15194. For micromobility devices: UL 2271 or UL 2272.
Who is liableBroader than NYC: it reaches manufacturers, assemblers and reconditioners, not only the seller.
Must appearThe certification or the laboratory's logo, wordmark or name on the packaging or documentation at the time of sale and directly on the product. Both, not either.
Penalty$500 for a first violation; up to $1,000 for each subsequent violation within two years. Each separate battery is a separate violation — a pallet of 400 packs is 400 violations.
EnforcementAttorney General, district attorneys and corporation counsel have concurrent authority to seek relief.
Separate companion law (S.7503-B) requires retailers to post battery safety information, with penalties up to $250 per unit on a first offence and $1,000 after.
California operativeHealth & Safety Code § 26300–26305
SB 1271, Stats. 2024 ch. 791 · effective 1 January 2025, operative 1 January 2026 · rentals from 1 January 2028
CertificationNo distribution, sale or lease of an e-bike unless its battery has been tested by an accredited testing laboratory to a standard referenced in ANSI/CAN/UL 2849 or EN 15194. Powered mobility device batteries: UL 2272. Storage batteries: UL 2271, or part of a complete system tested to UL 2849 / EN 15194.
Lab definedISO/IEC 17025 or 17065 accredited, or an OSHA-recognised NRTL. A supplier's own test house does not qualify.
Must appearThe laboratory's logo, wordmark, label or name and the applicable certification standard, permanently affixed directly on the e-bike or its electrical system, the device, the charger, or the battery. Secondhand sales are exempt from the marking rule.
Records§ 26304: a manufacturer, importer, distributor or retailer must provide, on request, a true and accurate copy of the test report issued by the laboratory. This is the widest record duty of the five.
PenaltyChapter 23 sets no penalty figure of its own. Enforcement runs through the State Fire Marshal and general consumer-protection routes. Treat the risk as injunctive and reputational, not a fixed fine.
Adjacent obligation: SB 501 (signed 2026) brings medium-format batteries — broadly, e-bike packs — into the state battery stewardship and collection programme. Secondary source; verify the operative date.
Illinois in force815 ILCS 361
Micromobility Fire Safety Act, P.A. 104-0414 (SB 2247) · effective 1 January 2026
CertificationLow-speed e-bike electrical drive system tested by an accredited laboratory: before 1 Jan 2028 to ANSI/CAN/UL 2849 or EN 15194; from 1 Jan 2028, UL 2849 only. Personal e-mobility devices: UL 2272. Traction battery for a low-speed e-bike: UL 2271, UL 2849 or EN 15194, narrowing to UL 2271 or UL 2849 in 2028.
Who is liableManufacturer, distributor, seller, lessor — and anyone who operates in furtherance of a business activity.
PenaltyA violation is an unlawful practice under the Consumer Fraud and Deceptive Business Practices Act, enforced by the Attorney General. That Act carries civil penalties far above the other four jurisdictions.
The 2028 narrowing is the one dated cliff in the whole map: an EN 15194-only certificate is enough today and not enough in fourteen months. Products certified today on EN 15194 alone need re-testing to UL 2849, not a new label.
Washington DC passed, not yet effectiveB.26-0244
Micromobility Fire Safety Standards Amendment Act of 2026 · passed Council 12–0, second reading 22 Sep 2026, signed 16 Oct 2026 · effective after 30-day congressional review
CertificationE-bikes: UL 2849 or EN 15194, and must bear the certification mark. Electric mobility devices: UL 2272. Traction batteries: UL 2271 or EN 50604.
TransitionShared fleet operators get six months in which e-bikes offered for rental may be certified to UL 2272 instead of UL 2849.
Must appearCertification mark on the device or battery. Secondhand sales are exempt from the marking rule.
PenaltyEnforcement sits with the District; the penalty schedule was not in the text verified here. Do not quote a figure.
Note the standard: DC names EN 50604 for traction batteries, where NYC, NY and Illinois name UL 2271. A pack certified only to UL 2271 is not automatically compliant in DC.
San Francisco passed, not yet effectiveFire Code amendment
Board of Supervisors vote 23 June 2026
What it doesAmends the city fire code to prohibit the sale and delivery of lithium-ion batteries and replacement batteries that do not meet specified certification requirements, with SFFD empowered to penalise sellers.
Why it mattersIt reaches delivery, not just the shop counter — the first municipal rule in this set framed around the last mile rather than the point of sale.
Verified from press reporting only. Confirm the signed text, the standards named and the effective date before relying on it.
Federal — proposed, not law
CPSC — 16 CFR Parts 1112 and 1265 proposed91 FR 38162 · Docket CPSC-2025-0012
NPR published 24 June 2026 · written comments closed 24 August 2026 · oral hearing 21 October 2026 · no final rule as at 10 November 2026
Would requireE-bike electrical systems to meet UL 2849-20, battery packs UL 2271-23, other micromobility devices UL 2272-24 — each with CPSC modifications on top.
AdditionsTamper-resistant battery enclosures; a post-discharge charge test ensuring the BMS refuses charging above a cell temperature limit; a reverse-polarity test; revised marking, labelling and instructions covering foreseeable misuse and thermal runaway.
ScopeWider than the state laws: user-replaceable packs sold separately, e-bike conversion kits, and aftermarket chargers.
Timing180 days after a final rule is published, applying to products manufactured after that date — existing stock is not recalled by the rule.
The proposal states that compliance with the current UL standards alone would probably not satisfy it, because CPSC adds requirements the standards do not contain. A supplier claiming "we are UL certified, so we are covered" is answering a different question.
Watch list — moving, not yet binding
New Jersey
A1875 / S2329 (introduced Jan 2026) would require accredited-lab testing of e-bike electrical systems and batteries before sale. Separate 2026 law (S4834/A6235) already imposes licensing and MVC registration from 19 July 2026 — registration needs a Manufacturer's Certificate of Origin.
Massachusetts
Ride Safe Act would tie e-bike legal status to UL certification. Bill stage.
Minnesota
Statute § 169.011 defines an e-bike partly by independent battery testing — a definitional hook rather than a sale prohibition.
Colorado
E-bike tax credit requires UL 2849 or EN 15194. A programme condition, not a market-access rule.
New York City
Int. 0988-2026 pending, would raise the first-violation penalty from $0 to $1,000 and tighten record and assembly rules.
What this means if you are the importer
One certificate does not cover a product line. UL 2849 certifies a defined combination: battery, charger, motor and controller tested together. Change the cell supplier, the BMS, the charger or the enclosure and the certificate no longer describes what you are shipping — which is the single most common way a compliant brand becomes non-compliant without anyone making a decision.
Three different questions. New York City asks whether the certification and the laboratory's identity are displayed. California asks whether you can produce the test report on request. Illinois routes a failure through consumer fraud. The same pack can satisfy one and fail another.
Marking duty is on the product, not only the box. New York State and California require the laboratory's mark affixed directly on the product; a certificate in a folder is not the obligation.
Shipping to one state is not a defence. If you sell online into any of these jurisdictions, the requirement attaches at the point of sale, and NYC enforces against online listings specifically.
The federal rule changes the standard, not just the paperwork. When 16 CFR 1265 is finalised, packs that meet today's UL standards without the CPSC additions will need engineering changes and re-testing, on a 180-day clock measured from manufacture.