EU Batteries Regulation: New Exemptions from Battery Replacement Requirements

As outlined in our previous article on the replaceability of batteries, from 18 February 2027, products containing portable batteries must generally be designed so that consumers can remove and replace the batteries themselves. The requirements primarily affect manufacturers and importers placing such products on the EU market. For certain product categories, exemptions apply on safety grounds, allowing battery replacement to be restricted to independent professionals. 

The European Commission has adopted new exemptions from the requirements governing the removability and replaceability of portable batteries. The exemptions cover, among other products,  

  • certain wearables,  

  • electric toys,  

  • ATEX products, 

  •  medical drug-delivery systems and  

  • specific telematics devices.  

For these products, battery replacement may be restricted to professionals where certain safety conditions are met and does not have to be possible for consumers. 

Companies concerned should first determine whether their products actually fall within one of the narrowly defined exemptions. Merely belonging to one of the relevant product categories may not be sufficient in every case. For wearables in particular, factors such as size, design and protection against water, dust and impact are relevant. 

From a compliance perspective, companies should therefore provide a clear and traceable justification in the technical documentation where a battery may only be replaced by professionals. This should include, in particular: 

  • the product’s precise legal classification; 

  • a documented safety and risk assessment; 

  • evidence explaining why the battery cannot be safely replaced by end users; 

  • requirements and instructions for replacement by independent professionals; and 

  • a review of the product design, user instructions, repair concept and spare-parts availability. 

The Commission’s updated guidelines clarify the concepts of an independent professional and a compatible replacement battery, as well as the interaction between these requirements and other EU product-safety legislation. 

Please note that for products incorporating portable batteries, companies must provide instructions and safety information on the use, removal and replacement of the batteries. This information must: 

  • be easy to understand 

  • be included with the products additionally 

  • published online in a permanently and publicly accessible format. 

We are happy to assist you with any questions. In particular, we can provide comprehensive advice on the information and labelling requirements applicable to electrical and electronic equipment (EEE), batteries and packaging.

Request one of our consulting packages here.