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EU Battery Removable New Regulations: Exemption for 8 Categories of Products Involving These Electronic and Electrical Products

Time：

2026-07-29

On July 14, 2026, the European Union adopted the revised version of Article 11 of the Battery and Waste Battery Regulation (EU) 2023/1542 regarding the requirements for the removal and replacement of portable batteries. This revision expands the exemption list for removable batteries, exempting 8 categories of products (the original 2 categories, this time adding 6 categories), and the 8 major categories of products do not need to meet the general requirement for portable battery users to replace them.

On July 14, 2026, the European Commission adopted the amendment to Article 11 of the Battery and Waste Battery Regulation (EU) 2023/1542 concerning the requirements for the removability and replaceability of portable batteries. This revision expands the list of exemptions for removable batteries, ultimately exempting eight categories of products (two existing categories and six newly added ones). These eight categories of products are not required to comply with the general mandatory requirements for user-replaceable portable batteries.

The next step involves the review and approval of this delegated act by the European Commission, after which it will be formally published in the Official Journal of the European Union. The regulation will enter into force 20 days after publication and will be directly applicable in all member states.

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EU Battery and Waste Battery Regulation

The EU Regulation on Batteries and Waste Batteries officially came into effect on August 17, 2023, with Article 11 establishing mandatory compliance obligations for portable batteries (up to 5kg, non industrial use).

Applicable products: All terminal products (smart wearables, small appliances, medical devices, portable instruments, etc.) that are launched in the EU market and have built-in portable batteries.

Universal mandatory requirement (user replaceable): Starting from February 18, 2027, it is mandatory for end users to have the entire battery set detachable and replaceable by default; Consumers can safely remove and replace batteries without the need for professional tools or repair qualifications. The legislative purpose is to reduce the overall disposal of products caused by battery scrap and increase the amount of waste battery recycling.

Exemption mode (only professional personnel can replace): Suitable for 8 major categories of products, it is not required for ordinary users to be able to remove and replace batteries. A professional repair and disassembly path must be reserved, and the manufacturer must provide repair drawings and adaptation tools. It is prohibited to completely weld or seal the battery without replacing it.

Policy adjustment logic: If a large number of micro integrated and special safety products are forced to be disassembled by users themselves, they are prone to safety hazards such as cell puncture, leakage, explosion, food contamination, and medical administration errors. Therefore, the EU has expanded the exemption list to balance environmental requirements and personal safety.

February 18, 2027 is the mandatory compliance deadline for detachable portable battery users. Export companies must assess in advance whether their products fall within the exemption scope, otherwise they need to adjust their product design plans in a timely manner.

Interpretation of This Revision

Revised regulations text

Regulation (EU) 2023/1542 on batteries and waste batteries, Article 11(2), as amended, reads as follows: (Additions are indicated in bold blue text.)

The content of Article 11(2) after revision

2. By way of exception to paragraph 1, products containing portable batteries listed below may be designed so that the batteries can only be removed and replaced by independent professionals:

(a) equipment designed specifically to operate primarily in environments that are frequently subject to splashing water, water streams, or water immersion and that is washable or rinseable, including wearable equipment;

(b) professional medical imaging and radiotherapy equipment as defined in Article 2(1) of Regulation (EU) 2017/745, and in vitro diagnostic medical devices as defined in Article 2(2) of Regulation (EU) 2017/746.

(c) Wearable devices whose safety, durability, or water resistance may be compromised by user access to the battery, and:

(1) Due to their nature, size, or shape, are considered too small to allow end-users to replace the battery properly and safely; or

(2) Rely on a compact, sealed enclosure to maintain functional integrity, including dust and shock resistance;

(d) Electric toys with built-in rechargeable batteries as of 31.07.2030, where an exemption is necessary due to the nature or size of the toy to ensure its safety when used in accordance with Article 10(2) of Directive 2009/48/EC of the European Parliament and of the Council;

(e) Wireless temperature probes specifically designed to come into contact with food during food preparation;

(f) Products falling within the scope of Article 1 of Directive 2014/34/EU;

(g) Externally applied systems specifically designed for subcutaneous drug delivery;

(h) Telematics devices intended for installation on the roofs of agricultural and construction machinery, designed to withstand severe vibrations, dust, and moisture during intended use.

The exemptions listed in paragraphs (a), (c), (d), (e), (f), (g), and (h) of this section shall apply only when such exemptions are necessary to ensure the safety of users and equipment.

List of 8 Categories of Exempt Products

Waterproof washing equipment (including waterproof wearables)

Electric toothbrush, dental irrigator, water washing beauty device, floor scrubber, waterproof smartwatch, waterproof TWS earphones, washable small appliances, etc. Ordinary users dismantle the machine and damage the sealed waterproof layer, causing water leakage and equipment scrapping, which poses a safety hazard.

Small wearable devices

Smart watches, fitness bracelets, smart glasses, textile electronic wearable devices, TWS Bluetooth earphones, etc. Exemption is granted if any of the following conditions are met:

(1) The body size is too small, which makes it easy for ordinary people to puncture the lithium battery during disassembly and assembly, causing a short circuit and fire;

(2) Relying on an integrated sealed shell to maintain dust-proof, waterproof, and shockproof core performance, dismantling the machine directly damages its overall functionality.

Rechargeable electric toys (temporary exemption, valid until July 31, 2030)

Batteries are small components, and there is a risk of accidental ingestion and electric shock for children when disassembling and assembling them. Children's toys with built-in rechargeable batteries will no longer be exempt from the new toy safety regulations starting from August 1, 2030.

Food contact wireless temperature probe

Special temperature probes for food processing, disassembly and sealing damage can cause battery electrolyte leakage, contaminate food ingredients, and pose a food safety risk.

ATEX explosion-proof equipment

Chemical, oil and gas, mine explosion-proof sensors, explosion-proof forklifts, explosion-proof pumps, explosion-proof motors, explosion-proof instruments, etc. The user disassembles the machine and generates sparks, which can easily trigger flammable and explosive environments.

Subcutaneous administration close fitting medical equipment

Insulin pumps, subcutaneous drug delivery wearable devices. Incorrect disassembly and assembly can result in abnormal dosage of medication, directly endangering the user's life and health.

Professional medical imaging, radiotherapy, in vitro diagnostic IVD large medical equipment

Large diagnostic and therapeutic instruments, radiation equipment, and laboratory diagnostic equipment in hospitals. Household blood glucose meters and monitors are not included in this category. Disassembling them without authorization can easily interfere with the accuracy of diagnosis and treatment, endangering patient safety.

Remote information terminal on the roof of agricultural and construction machinery vehicles

Long term exposure to harsh working conditions such as strong vibration, dust, and rain, and maintenance by only certified professionals, ordinary users are prone to short circuits and equipment loss of control when disassembling the machine.

Key Time Nodes

The regulation comes into force: It is directly applicable and legally binding throughout the EU on the 20th day after its publication in the Official Journal of the EU.

Uniform mandatory deadline for removable battery provisions: February 18, 2027, when all products exported to the EU must comply with the battery removability rule, with the exemption list implemented simultaneously.

Temporary exemption deadline for electric toys: July 31, 2030, after which products must be redesigned according to the new rules.

High-frequency pitfalls

Misconception 1: Product inclusion in exemption=completely uncontrolled, batteries can be permanently sealed without providing replacement channels

Correction: Only the end user is exempted from the obligation to disassemble the device themselves. The product still needs to be equipped with professional maintenance channels and complete compliance technical documents. Certified professional maintenance personnel must be able to completely replace the battery, and the manufacturer must provide long-term spare parts for the matching battery.

Misconception 2: Power banks and headphone charging compartments should also have detachable structures

Correction: The official guide clearly states that independent sales of power banks, TWS headphone charging cases, and car emergency start power supplies are all portable batteries and are not subject to the detachable clause of Article 11! Power banks do not need to be designed with user detachable or professional detachable structures. The integrated sealing, ultrasonic welding, and adhesive packaging solutions can all be retained, and only need to comply with the basic obligations of battery laws such as hazardous substances, labels, QR codes, EPR recycling registration, and waste battery labeling.

Misconception 3: The new regulations come into effect immediately, and companies need to rectify them immediately

Correction: The bill will officially come into effect 20 days after the parliament has no objections, but the detachable provisions will be uniformly enforced on February 18, 2027, and companies will have sufficient window for rectification.

Misconception 4: Products with IP waterproof rating can automatically enjoy exemption

Correction: IP waterproofing is only a reference indicator, and companies must provide complete technical documentation to prove that they cannot redesign to avoid security risks. Otherwise, regulatory agencies may reject the exemption eligibility.

Misconception 5: Software pop-up prompts that non original batteries are a violation of locking the device

Correction: Only pop-up text prompts compliance, as long as the basic usage functions of the device are not restricted, it does not constitute a violation of pairing and locking.

Compliance Recommendations

The EU battery regulations have multiple dimensions of control and a long implementation cycle. In addition to the rules for battery disassembly, multiple requirements such as carbon footprint, battery digital passport, and recycling indicators have been implemented one after another. Batteries are a key technology for sustainable development, green transportation, clean energy, and climate neutrality. Portable batteries are being used to power an increasing number of products, from wearable devices to toys, textiles, or medical devices.

The revision of the detachable provisions of the EU Battery Law balances the needs of product miniaturization, waterproof and explosion-proof safety, and circular environmental protection, significantly reducing the structural renovation costs for manufacturers of wearable digital, small household appliances, and industrial explosion-proof equipment; This is a significant policy benefit for the power bank industry, and there is no need to adjust the existing mature integrated packaging design.

The universal requirement for portable battery users to replace batteries is mandatory to be implemented on February 18, 2027. It is recommended that all foreign trade enterprises exporting to the European Union complete product classification, compliance document sorting, and label QR code layout as soon as possible to avoid the risk of product clearance obstruction and EU market delisting penalties in the later stage.

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