EU Batteries Regulation Removability and replaceability FAQ

From 18 February 2027, products placed on the market with incorporated portable batteries are subject to the default rule of end-user removability and replaceability throughout the product's lifetime. The obligation applies to the whole portable battery, not to individual cells or other parts inside it.

Products incorporating LMT batteries must allow an independent professional to remove and replace the LMT battery and the individual cells in its pack throughout the product's lifetime.

A portable battery is sealed, weighs no more than 5 kg, is not designed specifically for industrial use, and is not an EV, LMT, or SLI battery. An LMT battery is a sealed traction battery weighing no more than 25 kg for a wheeled vehicle powered by an electric motor alone or by motor and human power; it excludes an electric vehicle battery. Apply the complete Article 3 definitions to the product rather than classifying it by size or marketing name alone.

The Commission updated its interpretation in Notice C(2026) 5032 final, dated 14 July 2026. Use that notice for current guidance alongside Article 11 and any applicable delegated act. Its explanations and examples are non-binding; the notice alone does not establish a product exemption.

A portable battery is readily removable by the end user when it can be removed with commercially available tools. Removal cannot require proprietary tools, thermal energy, or solvents. A specialised tool is permissible only if it is supplied free of charge with the product.

The Commission notice explains the end user as an adult without specific experience or qualifications for removing or replacing batteries. A design review should therefore test whether the published instructions, tool assumptions, fasteners, connectors, adhesives, enclosure, and hazard controls match that user profile.

For LMT batteries, Article 11 itself uses independent professionals as the required removal and replacement actor. The Commission notice describes independent professionals as independent operators with the technical competence and qualification to repair the product, or to restore battery function when cell-level work is performed.

For portable batteries, professional-only removal is a derogation from the end-user rule. Article 11 supports this only for listed categories, such as certain wet-environment appliances where safety requires it and certain professional medical imaging, radiotherapy, and in vitro diagnostic medical devices. The wet-environment derogation needs product documentation showing that end-user replacement would compromise safety and that redesign is not possible with the current state of the art without severely affecting health and safety or product performance and functionality.

Article 11 removes the portable-battery end-user obligation where continuity of power supply and a permanent battery connection are necessary for user and appliance safety, or for data integrity where the product's main function is to collect and supply data.

The Commission notice gives non-binding examples and explains the data-integrity boundary: data collection as an additional feature is not enough, and the derogation does not apply where the product's primary data function presents no integrity risk, for example because it uses non-volatile memory. Each claimed derogation needs evidence for every condition in Article 11(3).

Article 11 requires products incorporating portable batteries to have instructions and safety information for use, removal, and replacement. The information must remain online on a public website and be easily understandable to end users. For both portable and LMT batteries, the Commission notice strongly recommends including replacement instructions and the technical specifications a compatible battery must meet.

For products placed on the market from 18 February 2027, portable and LMT batteries must be available as spare parts for at least five years after the last unit of the equipment model is placed on the market, at a reasonable and non-discriminatory price for independent professionals and end users. Software must not impede replacement with a compatible battery or compatible key components.

The Article 11 evidence file should let a product, legal, quality, or market-surveillance reviewer trace the incorporated battery category to the design choice. It should also show that the public instructions, spare-parts route, and software behavior match the product placed on the market.

A derogation record should identify the exact Article 11 basis, the facts satisfying every condition, the internal approval, and any applicable requirements under other EU product law. For a delegated category, also record the act's Official Journal publication, entry-into-force date, and product criteria before relying on it.