Before 18 February 2027, businesses should check whether products with built-in batteries will meet the new EU requirements. This mainly concerns the product design, the possibility of safely removing and replacing the battery, instructions, technical documentation and the availability of the battery as a spare part. It is worth doing this in advance, as some changes may require product redesign, documentation updates or refinement of the service process.
We have already discussed the topic of replaceable batteries from 2027 in the context of changes in electronics design. In this article, we focus on the practical requirements that should be analysed before Article 11 of Regulation (EU) 2023/1542 enters into application.
Products with built-in batteries are now used in many industries. This applies not only to consumer electronics, but also to household appliances, tools, toys, medical devices, smart products, sensors, terminals, electric bicycles and light means of transport. This group also includes wearable devices, such as smartwatches, sports bands and medical sensors. The more such products are placed on the market, the more important their durability, repairability and safe battery replacement become.
Regulation (EU) 2023/1542 on batteries and waste batteries introduces requirements that must be taken into account already at the product design stage. Article 11 of the regulation is particularly important. It will apply from 18 February 2027 and concerns the possibility of removing and replacing portable batteries and LMT batteries, meaning batteries used in light means of transport.
For manufacturers, importers and operators placing products on the EU market, this means the need to check the product design, documentation, instructions, access to spare parts and any technical restrictions in advance.
What is the new requirement?
The main principle is simple: a battery built into a product should be safely removable and replaceable. However, this does not only mean the physical removal of the battery. Replacement should not damage the battery or the device. After replacement, the product should still operate as intended. Its safety, functionality or performance must not deteriorate.
In the case of portable batteries, the obligation generally concerns the possibility of removal and replacement by the end-user. This means an adult who does not have specialist knowledge or repair qualifications. The product should therefore be designed so that the user can carry out this operation safely and without damaging the device.
In the case of LMT batteries, the requirements refer to the possibility of removal and replacement by independent professionals. This also applies at the level of the cells forming part of the battery.
Tools, instructions and the practical possibility of replacement
A manufacturer’s declaration that the battery is replaceable is not enough. What matters is the practical possibility of carrying out this operation.
A portable battery should be removable either without tools or using tools available on the market. It should not be necessary to use proprietary tools, solvents, heat energy or methods that could damage the device. If a specialist tool is required for replacement, it should be supplied free of charge with the product.
For businesses, this means the need to check the product design. It is necessary to assess whether the battery is not permanently potted, glued in a way that makes disassembly difficult, enclosed in a housing that requires destruction, or protected by elements that the user will not be able to remove safely.
Instructions are equally important. The user or professional should receive clear information on how to remove the battery, how to replace it and how to handle the waste battery. The instructions should also indicate the rules for safe storage, transport and handover of the waste battery to an appropriate collection point.
When will replacement by the user not be required?
The regulation provides for exceptions. In some cases, it is sufficient for the battery to be removable and replaceable by an independent professional.
This applies, among other things, to selected products specifically designed for use in a wet environment. These are devices that are regularly exposed to splashing, water jets or immersion and are intended to be washed or rinsed. Examples may include some electric toothbrushes, shavers, hair clippers or epilators.
However, this does not mean that every product with an IP rating automatically qualifies for the exception. The manufacturer should have a technical justification. It must be demonstrated that the product does in fact operate mainly in such an environment and that battery replacement by the user could pose a risk to the safety of the user or the device itself. It must also be shown that redesigning the product is not possible without a serious impact on the safety, function or operation of the product.
Separate exceptions may also apply to certain medical devices, devices that are essential for safety, and products in which a permanent connection between the battery and the device is necessary for data integrity reasons.
Battery as a spare part
The new requirements also concern battery availability after the product has been sold. Portable batteries and LMT batteries must be available as spare parts for at least 5 years from the placing on the market of the last unit of a given equipment model.
This is important for manufacturers and importers, as battery availability must be planned in advance. It is not enough to design a product with a replaceable battery. It is also necessary to ensure that replacement can actually be carried out during the product’s lifetime.
If additional elements are required for replacement, such as connectors, screws, seals or other fasteners, they may also need to be available as spare parts. This is particularly important when they cannot be reused after disassembly.
Compatible battery and software restrictions
The regulation also draws attention to compatible batteries. The product should allow the use of both an original battery and a compatible battery, provided that such a battery does not create a hazard and allows the device to operate as intended.
Software restrictions are also important. Software should not make it difficult to replace a battery with a compatible one. This applies, among other things, to practices involving the pairing of parts with a specific device unit. The manufacturer may use solutions that ensure product safety and proper operation, but should not block repair or limit the functions of the device solely because a compatible battery has been used.
It may be acceptable to inform the user that a non-original battery has been used. However, such a message should not affect the operation of the product, the compatible battery or the user experience.
What should businesses plan before 18 February 2027?
Businesses placing products with built-in batteries on the EU market should already check whether their products will meet the new requirements. It is worth analysing the device design, the method of battery installation, access to tools, user instructions, technical documentation and the availability of batteries as spare parts.
In practice, it is worth answering several questions:
- Can the end-user safely remove and replace the battery?
- How does replacement affect the device and does it cause any damage?
- What tools are needed to remove and replace the battery?
- Are these tools available on the market?
- How do the instructions describe battery replacement and handling of the waste battery?
- For how long will the battery be available as a spare part?
- Does the software block the use of a compatible battery?
- On what basis can any exception from the obligation be technically and documentarily justified?
Technical support in preparing products for the new requirements
The new requirements should not be treated as a purely legal issue. They are primarily a design, technical and documentation matter. They concern the way the product is designed, user safety, instructions, spare parts and conformity assessment.
RCC supports manufacturers, importers and distributors in analysing technical requirements and product documentation for products placed on the EU market. In the case of products with built-in batteries, it may be helpful to check whether the device design, the method of battery installation, instructions and documentation comply with the new requirements.
Good preparation before 18 February 2027 will help reduce the risk of later design changes, documentation problems and delays in placing products on the market. For battery-powered devices, battery replaceability should therefore be treated as a permanent element of product design, not as a formality at the end of the process.