Battery removability and replaceability

Article 11 applies from 18 February 2027. The Commission Notice states that the spare-battery requirement does not apply to products incorporating portable or LMT batteries that were placed on the market before that date. Keep evidence of the date each product unit was first made available on the EU market; a design date, manufacturing date, or later resale date does not answer that question by itself.

Article 11(1) also preserves EU electrical and electronic equipment rules that provide a higher level of protection for portable-battery removability and replaceability. For smartphones, mobile phones other than smartphones, cordless phones, and slate tablets covered by Regulation (EU) 2023/1670, the Commission Notice says that regulation's removability and replaceability rules prevail where they are more specific. Its spare-parts and serialisation requirements can apply alongside Article 11.

A portable battery incorporated into a product generally must be removable and replaceable by the end-user at any time during the product lifetime. The rule applies to the entire portable battery, not to individual cells or other parts inside it. The Commission Notice interprets an end-user here as an adult without specific battery-removal experience or qualifications.

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.

An 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.

Article 11 prohibits using software to impede replacement of a portable battery, LMT battery, or their key components with another compatible battery or compatible key components. The Commission Notice says software may establish communication needed for correct and safe function. It may also notify a user that a non-original spare battery is installed, but the notification must not affect device or battery functionality or the user experience.

For products placed on the market from 18 February 2027, Article 11 requires portable 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 gives non-binding implementation guidance. If replacement requires fasteners that cannot be reused, those fasteners should also be available as spare parts. The Notice strongly recommends including safe replacement instructions and the technical specifications that compatible batteries need to meet. Covered phones and slate tablets can have a longer seven-year spare-parts period under Regulation (EU) 2023/1670, so check both instruments.

Article 11 allows two product groups with portable batteries to use independent-professional removal and replacement instead of end-user replacement. The first covers appliances specifically designed to operate primarily where they are regularly subject to splashing water, water streams, or water immersion, and intended to be washable or rinseable, but only where the derogation is required for user and appliance safety. The second covers professional medical imaging and radiotherapy devices under Regulation (EU) 2017/745 and in vitro diagnostic medical devices under Regulation (EU) 2017/746.

A separate full derogation removes the paragraph 1 duties where continuity of power is necessary and a permanent connection between the product and portable battery is required for user and appliance safety. It also covers data-integrity cases where collecting and supplying data is the product's main function and the permanent connection is required for data integrity. A secondary data feature, or a design with no risk of data loss, does not satisfy the Commission Notice's interpretation of that test.

The non-binding Commission Notice says an IP rating alone does not establish the wet-environment derogation. The file should show that the appliance is specifically and primarily designed for the stated environment, is washable or rinseable, end-user replacement would compromise safety, and redesign is not feasible with current technology without severely affecting health and safety, performance, or functionality.

An Article 11 file should connect the product design to the applicable paragraph. 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 evidence satisfies every condition of a claimed derogation.

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.