Battery Removability Requirements Become Mandatory in 2027: Time to Prepare
The clock is ticking: from 18 February 2027, the requirements set out in Article 11 of the EU Battery Regulation (EU) 2023/1542 will become mandatory. From that date, portable batteries and batteries for light means of transport (LMT batteries) integrated into products must be readily removable and replaceable.
While this may initially appear to be a purely technical requirement, it has far-reaching implications for product design, supply chains, technical documentation, and compliance processes. Companies should use the remaining time to prepare their products and internal procedures for these new obligations.
Who is affected?
The requirements apply to all economic operators placing products with integrated portable or LMT batteries on the EU market, including manufacturers, importers, and distributors of:
Smartphones and tablets
Laptops and other portable electronic devices
Household appliances and small electronic equipment
E-bikes and e-scooters
Other products containing integrated batteries
What will apply from February 2027?
Portable Batteries
Portable batteries must be removable and replaceable by the end user throughout the product's lifetime using commercially available tools and without causing damage to either the device or the battery.
Exceptions are permitted only in limited cases, such as certain waterproof devices or medical products. Any exception must be properly justified and documented.
LMT Batteries
Batteries for light means of transport must be designed so that they can be easily removed and replaced by independent professionals.
Further Guidance from the European Commission
The European Commission has already provided important clarification through its guidance document C(2025)214. The guidance further specifies criteria for "easy removability," tool requirements, as well as evidence and documentation obligations.
Companies that take action early will not only reduce regulatory risks but also avoid costly product redesigns, recalls, and potential enforcement measures by market surveillance authorities.
September Training Courses: How to Achieve Compliance
Would you like to understand which products are affected, how the requirements of the EU Battery Regulation should be interpreted, and what practical steps your company needs to take now?
In our September training courses, our experts provide a practical and comprehensive overview of the new battery removability and replaceability requirements. Participants will gain insight into the legal framework, the latest European Commission guidance, and concrete recommendations for product development, procurement, product management, and compliance teams.
