The European Commission has published guidelines aimed at clarifying the uniform application of regulations concerning the removability and replaceability of portable batteries and light electric vehicle batteries (LMT batteries) under the EU Battery Regulation (EU) 2023/1542. The guidelines provide technical recommendations and illustrative examples that are not legally binding. Article 11 of the regulation will apply from February 18, 2027. The purpose of the guidelines is to ensure sustainable and safe practices for handling and replacing batteries throughout the product’s lifecycle.
Key principles of battery removability and replaceability
Under Article 11, anyone placing products equipped with portable batteries or batteries on the market must ensure that the batteries can be easily removed and replaced by the end user throughout the product’s entire lifespan. However, this requirement does not apply to individual cells or other components of battery units.
The requirements for LMT batteries differ from the above. Those placing products with LMT batteries on the market must ensure that both the batteries and individual battery cells within the battery unit can be easily removed and replaced by independent professionals throughout the product’s entire lifespan.
- Removability means that the end user or an independent professional can safely remove the battery without damaging the device or the battery itself.
- Replaceability requires that the battery can be replaced without causing damage, maintaining the device’s performance and safety.
Exceptions to the removability requirements
In certain cases, the end user does not need to be able to remove and replace the battery themselves. These exceptions include:
- Devices operating in wet environments, such as those exposed to washing water.
- Professional medical imaging and radiation therapy devices, as well as in vitro diagnostic devices.
- Devices requiring continuous power supply for user safety or data integrity, such as certain medical devices and equipment that continuously collect and transmit data.
Exceptions apply only if redesigning the device does not allow for safe battery replacement by the end user.
Additional considerations
Compatible batteries
A compatible battery or battery unit must:
- Not pose a safety risk to the user or device.
- Allow the device to function as intended.
- Match the original battery in technical parameters, such as capacity and chemical composition.
If the device falls under the type-approval requirements of Regulation (EU) No 168/2013, battery replacement is permitted only if it does not affect type-approval definitions. For LMT vehicles that do not require type approval, battery replacement must comply with the manufacturer’s safety protocols.
Software restrictions
Software must not prevent the replacement of compatible batteries. For example, “parts-pairing” practices, where a battery is software-locked to a specific device, are not allowed. However, software may ensure secure communication between the device and the battery to guarantee safety and functionality.
Under Regulation (EU) 2023/1670, which sets ecodesign requirements for smartphones and tablets, manufacturers must provide professional repairers with non-discriminatory access to software and tools ensuring the full functionality of spare parts. If both regulations (EU) 2023/1542 and (EU) 2023/1670 apply to the same product, the requirements of both must be followed.
Availability of spare parts
Under Article 11(7), portable batteries and LMT batteries must be available as spare parts for at least five years after the last model of the device is placed on the market. These must be offered at a reasonable and non-discriminatory price to independent professionals and end users. Spare parts, such as fasteners, must be delivered within five working days of ordering. If fasteners are not reusable, they must be provided separately. This requirement does not apply to products placed on the market before February 18, 2027.
Under Regulation (EU) 2023/1670, from June 20, 2025, phone manufacturers, importers, or authorized representatives must ensure that portable batteries and necessary fasteners remain available for professional repairers and end users for at least seven years after the last model of the device is placed on the market. If both regulations (EU) 2023/1542 and (EU) 2023/1670 apply to the same product, both must be complied with simultaneously to ensure the availability and compatibility of spare parts.
Recommendations
- User manuals: Instructions should provide clear guidance on removing and replacing batteries, as well as technical specifications for compatible alternatives. If necessary, manuals should reference EU or international standards to ensure safety.
- Recycling: Users should receive clear instructions on the proper recycling of batteries, especially small lithium batteries and lithium-ion batteries used in products such as greeting cards and e-cigarettes, as these pose a fire hazard in waste treatment facilities.
Link to the Commission’s guidelines
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