Battery Regulation: New Guidelines on Removability Requirements

Starting February 18, 2027, manufacturers must ensure portable and light mobility (LMT) batteries can be easily removed and replaced by end users, according to Article 11 of the EU Batteries Regulation (2023/1542).
The European Commission published guidance in January 2025 clarifying limited exemptions to these requirements. Products designed for wet environments and certain medical devices may qualify for exemptions, but manufacturers must provide solid evidence showing that:

• Battery removal by users would create safety risks
• Redesigning the product is not possible with current technology without compromising safety or functionality

These exemptions aren't automatic - manufacturers must document their justification before placing products on the market. Even exempt products must still allow battery replacement by independent professionals. The guidance specifies that battery removal must be possible without damaging the device or battery, and any required tools must be commonly available rather than proprietary (Link to guide). 

Companies selling products with built-in batteries in the EU should review their designs now to determine if they comply with these requirements or if they genuinely qualify for exemptions. With the deadline less than two years away, some products may need significant redesign to meet these new standards.