We heard batteries must be removable by the user

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 The article applies from 18 February 2027 (Article 96(2)(a)); until then, Article 11 of the repealed Directive 2006/66/EC continues to apply (Article 95(a)).^[1]

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).^[1]

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)).^[1]

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)).^[1]