Standard Interpretation | Draft Exemption List for Removability and Replaceability of Portable Batteries under the EU
Pursuant to the EU Batteries Regulation (EU) 2023/1542, from 18 February 2027, all products incorporating portable batteries shall be designed to ensure that such batteries are readily removable and replaceable by the end-user throughout the product’s lifetime.
Recently, the European Commission published a draft list of exemptions for portable batteries, revising and expanding the provisions set out in the original Regulation. A public consultation has been launched and will remain open until 26 May 2026.
Which Products Can Be Exempt?
The following categories of products may be designed such that battery removal and replacement are carried out only by an independent professional, rather than by the end-user:
(a) Equipment intended for use in environments involving splashes, water jets, or immersion, including appliances that are washable or rinsable (including wearable devices);
(b) Professional medical imaging and radiotherapy equipment covered by Regulation (EU) 2017/745, and in vitro diagnostic medical devices covered by Regulation (EU) 2017/746;
(c) Wearable devices where user access to the battery may compromise safety, durability, or water resistance, and which meet at least one of the following conditions:
- The battery is too small, due to its nature, size, or shape, to allow safe and proper replacement by the end-user;
- The device relies on a compact and sealed enclosure to maintain functional integrity, including protection against dust and mechanical stress;
(d) Electric toys powered by rechargeable batteries, until 31 July 2030;
(e) Wireless temperature probe devices specifically designed to come into contact with food during food processing;
(f) Products falling within the scope of Directive 2014/34/EU (equipment intended for use in potentially explosive atmospheres);
(g) Implantable or body-worn drug delivery systems designed for subcutaneous administration of medicinal products;
(h) Remote communication devices installed on agricultural and construction machinery, capable of withstanding severe vibration, dust, and humid conditions during intended use.
Note: These exemptions apply only where strictly necessary to ensure the safety of users and equipment.
Compared with the existing exemptions, this draft introduces the following additions:
- Wearable devices under point (a);
- The categories listed under points (c) to (h).
Further Focus: Battery Removability Requirements for Mobile Phones and Tablets
In addition to the EU Batteries Regulation, the EU Ecodesign requirements for mobile phones and tablets also establishes exemption conditions from end-user battery removability requirements. Under this framework, the obligations on removability and replaceability take precedence over those set out in the Batteries Regulation.
For further details, please refer to: [Key Compliance Points for Batteries under the EU Ecodesign Requirements for Mobile Phones and Tablets]
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