{
  "type": "problem",
  "slug": "battery-removability",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/battery-removability/",
  "markdown": "https://www.conphora.com/solutions/problem/battery-removability.md",
  "title": "We heard batteries must be removable by the user",
  "description": "Battery Regulation Article 11: from 18 February 2027 portable batteries in products must be removable and replaceable by the end-user. The exceptions.",
  "answer": "From 18 February 2027, Article 11 of the Battery Regulation (EU) 2023/1542 requires anyone placing on the market a product with a portable battery to make it readily removable and replaceable by the end-user. Derogations are narrow; LMT batteries must be replaceable by independent professionals. Spare batteries stay available at least five years after the last unit of the model is placed on the market; software may not block replacement.",
  "theme": {
    "id": "batteries-electronics",
    "label": "Batteries and electronics"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    }
  ],
  "regulations": [
    "BattR"
  ],
  "path": [
    "regulation-library",
    "compliance-radar"
  ],
  "trigger": "Product development is planning a model that will still be on sale after 18 February 2027, and the battery is glued in",
  "keep": null,
  "why": [
    {
      "text": "Article 11 of the Battery Regulation (EU) 2023/1542 is a design rule placed on the product, not only on the battery. Any natural or legal person that places on the market products incorporating portable batteries must ensure that those batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product (Article 11(1)). The obligation concerns entire batteries, not individual cells. The article applies from 18 February 2027 (Article 96(2)(a)); until then, Article 11 of the repealed Directive 2006/66/EC continues to apply (Article 95(a)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The regulation defines what \"readily removable\" means. A portable battery is readily removable by the end-user where it can be removed with commercially available tools, without specialised tools (unless provided free of charge with the product), proprietary tools, thermal energy or solvents (Article 11(1), second subparagraph). It is readily replaceable where, after removal, it can be substituted by a compatible battery without affecting the functioning, performance or safety of the appliance (Article 11(6)). The product must come with instructions and safety information on use, removal and replacement, made available permanently online on a publicly available website (Article 11(1), third subparagraph).",
      "sources": [
        1
      ]
    },
    {
      "text": "The exceptions are specific. Appliances designed to operate primarily in an environment regularly subject to splashing water, water streams or water immersion, intended to be washable or rinseable, may be designed so that only independent professionals can remove the battery, but only where that is required for the safety of the user and the appliance. Professional medical imaging and radiotherapy devices and in vitro diagnostic medical devices may also be designed that way (Article 11(2)). The removability obligation does not apply where continuity of power supply and a permanent connection between product and battery are required for safety or, for products whose main function is to collect and supply data, for data integrity (Article 11(3)). The Commission may add further exemptions by delegated act on safety grounds (Article 11(4)) and is to publish guidelines on the article (Article 11(9)).",
      "sources": [
        1
      ]
    },
    {
      "text": "Two further duties extend the rule into the product's life. Portable and LMT batteries must be available as spare parts for a minimum of 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 (Article 11(7)). Software must not be used to impede the replacement of a portable or LMT battery, or of their key components, with a compatible one (Article 11(8)). For light means of transport, the battery and its individual cells must be readily removable and replaceable by an independent professional (Article 11(5)).",
      "sources": [
        1
      ]
    }
  ],
  "steps": [
    {
      "name": "List the products that will be placed on the market after the date",
      "text": "Article 11 applies from 18 February 2027. Start with the models you will still place on the market after that date and note, for each, the battery category: portable, LMT or other. Only portable and LMT batteries are covered by Article 11.",
      "item": "regulation-library"
    },
    {
      "name": "Test removal against the regulation's definition",
      "text": "A portable battery is readily removable by the end-user where it can be taken out with commercially available tools, without specialised or proprietary tools, thermal energy or solvents. A specialised tool counts only if it is supplied free of charge with the product. After removal, a compatible battery must be able to replace it without affecting function, performance or safety."
    },
    {
      "name": "Check honestly whether a derogation applies",
      "text": "The derogations are narrow: appliances designed to operate primarily in an environment regularly subject to splashing water, water streams or immersion and intended to be washable or rinseable, where needed for safety; certain professional medical imaging, radiotherapy and in vitro diagnostic devices; and products where continuity of power supply and a permanent connection are required for safety or, for data-collecting products, for data integrity. Document the reasoning."
    },
    {
      "name": "Write the removal instructions and publish them online",
      "text": "Products must come with instructions and safety information on the use, removal and replacement of the batteries, made available permanently online on a publicly available website, in a way end-users can understand."
    },
    {
      "name": "Secure spare batteries and remove software locks",
      "text": "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. Software must not be used to impede replacement with a compatible battery or key components."
    },
    {
      "name": "Follow the Commission's guidelines and any added exemptions",
      "text": "The Commission is to publish guidelines on the harmonised application of Article 11 (Article 11(9)) and may add exempted products by delegated act (Article 11(4)). Watch for both before you fix the design.",
      "item": "compliance-radar"
    }
  ],
  "documents": [
    {
      "name": "Instructions and safety information on use, removal and replacement",
      "from": "The person placing the product on the market",
      "ground": "Battery Regulation Article 11(1), third subparagraph"
    },
    {
      "name": "The reasoning for any derogation relied on",
      "from": "The manufacturer",
      "ground": "Battery Regulation Article 11(2)–(3) (the article prescribes no record; documenting the reasoning is good practice)"
    },
    {
      "name": "Spare-part availability and pricing for the battery",
      "from": "The person placing the product on the market",
      "ground": "Battery Regulation Article 11(7)"
    }
  ],
  "risks": [
    {
      "title": "Authorities can require corrective action",
      "text": "Where the authority has sufficient reason to believe a battery presents a risk and its evaluation finds the battery non-compliant, it requires the economic operator to bring it into compliance, withdraw it or recall it within a reasonable period, and takes provisional measures itself if the operator does not act (Battery Regulation Article 79(1) and 79(4)). Other non-compliance is handled under Regulation (EU) 2019/1020, Article 16, which covers the Battery Regulation (Annex I, point 21).",
      "source": 1
    },
    {
      "title": "Corrective action covers every market",
      "text": "The economic operator ensures that corrective action is taken for all the non-compliant batteries it has made available on the market throughout the Union (Battery Regulation Article 79(3)).",
      "source": 1
    },
    {
      "title": "Penalties under national law",
      "text": "Member States lay down effective, proportionate and dissuasive penalties for infringements of the regulation (Battery Regulation Article 93).",
      "source": 1
    }
  ],
  "faq": [
    {
      "q": "From when does the rule apply?",
      "a": "From 18 February 2027 (Battery Regulation Article 96(2)(a)). Until then, Article 11 of the repealed Directive 2006/66/EC continues to apply (Article 95(a))."
    },
    {
      "q": "Does it apply to individual cells?",
      "a": "No. The obligation applies only to entire batteries and not to individual cells or other parts included in them (Battery Regulation Article 11(1))."
    },
    {
      "q": "May we require a screwdriver?",
      "a": "Yes, if it is commercially available. What is excluded is the need for specialised tools (unless supplied free with the product), proprietary tools, thermal energy or solvents to disassemble the product (Article 11(1), second subparagraph)."
    },
    {
      "q": "What about e-bike batteries?",
      "a": "LMT batteries, and the individual cells in the battery pack, must be readily removable and replaceable by an independent professional, not necessarily by the end-user (Battery Regulation Article 11(5))."
    },
    {
      "q": "Can a firmware check refuse third-party batteries?",
      "a": "Software shall not be used to impede the replacement of a portable or LMT battery, or of their key components, with another compatible battery or key components (Battery Regulation Article 11(8))."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20260813",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/1542 concerning batteries and waste batteries (Official Journal L 191, 28.7.2023)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/eli/reg/2023/1542/oj",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "battery-in-product",
    "battery-labelling",
    "battery-passport",
    "new-regulation"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}