Battery removability and replaceability

For products incorporating portable batteries, the core rule is end-user removability and replaceability throughout the product lifetime. The rule applies to the entire portable battery, not to individual cells or other parts inside that battery.

A portable battery is readily removable by the end-user when it can be removed with commercially available tools. Article 11 rules out reliance on specialised tools unless those tools are supplied free of charge with the product, and it also rules out proprietary tools, thermal energy, or solvents to disassemble the product.

The product must come with instructions and safety information on battery use, removal, and replacement. Those instructions must also remain permanently available online on a public website in a way end-users can understand.

For light means of transport, Article 11 uses a different actor: the LMT battery must be readily removable and replaceable by an independent professional, not necessarily by the end-user. The obligation also reaches individual battery cells included in the LMT battery pack.

The Commission Notice treats independent professionals as independent operators with the technical competence and qualifications to repair the product into which the battery is integrated. If work is done at individual-cell level in an LMT battery pack, the professional should have the competence to restore the battery so it operates as intended.

Article 11 treats a portable or LMT battery as readily replaceable only when, after removal, it can be substituted by another compatible battery without affecting the functioning, performance, or safety of the appliance or light means of transport.

The Commission Notice explains that a compatible battery must not create a safety risk for the user or device and must allow the device to operate as intended. For multi-cell batteries, compatibility also depends on technical parameters such as capacity, state of health, design, and chemistry.

Software cannot be used to impede replacement of a portable battery, LMT battery, or key components with another compatible battery or key components. Software may support communication needed for safe and correct function, but it should not block repair or degrade the user experience merely because a compatible non-original battery is used.

Article 11 requires portable batteries and LMT batteries to remain available as spare parts for the equipment they power for at least five years after the last unit of the equipment model is placed on the market. The price must be reasonable and non-discriminatory for independent professionals and end-users.

The Commission Notice adds practical detail: if replacement requires physical elements such as fasteners and those fasteners are not reusable, those fasteners should also be available as spare parts. Instructions should identify safe replacement steps and the technical specifications that compatible batteries need to meet.

Article 11 allows some portable-battery products to be removable and replaceable only by independent professionals instead of end-users. The listed cases are products designed primarily for wet environments that are washable or rinseable, where the derogation is required for user and appliance safety, and certain professional medical imaging, radiotherapy, and in vitro diagnostic medical devices.

Article 11 also removes the paragraph 1 obligations where continuity of power supply and a permanent connection are necessary for user and appliance safety, or for data integrity in products whose main function is collecting and supplying data.

The Commission Notice stresses that wet-environment evidence should not rest on an IP rating alone. Useful evidence shows the appliance is specifically and primarily designed for the wet environment, is intended to be washable or rinseable, end-user replacement would compromise safety, and redesign is not feasible with the current state of the art without severely affecting safety, performance, or functionality.

A useful Article 11 file connects the product design to the exact Batteries Regulation rule. It should show whether the battery is portable or LMT, who can remove and replace it, what tools and instructions are needed, whether compatible batteries are supported, and whether any derogation is justified by evidence rather than preference.

Do not mix Article 11 evidence with unrelated Batteries Regulation records unless those records are needed for a separate requirement. For removability and replaceability, the decisive records are design, safety, repairability, spare-part, instruction, software, and compatibility evidence.