Removability and Replaceability: What the EU Battery Regulation Requires, for Which Batteries and From When

The rule sits in Regulation (EU) 2023/1542 concerning batteries and waste batteries (OJ L 191, 28.7.2023, p. 1), which is directly applicable in every member state without national transposition. Article 11 belongs to Chapter II, beside the substance, carbon footprint, recycled content, performance and safety rules of the EU Battery Regulation.

Article 11 concerns the design of the product that carries the battery, not the battery as sold on its own. The sections below follow Article 11 paragraph by paragraph: scope, dates, the tool test, LMT batteries, derogations, spare batteries and software, status, duty holder and proof.

What Does Article 11 Require?

Article 11 requires any natural or legal person that places on the market a product incorporating a portable battery to ensure that the battery is readily removable and replaceable by the end-user at any time during the lifetime of the product.

The obligation covers entire batteries, not individual cells or other parts (Article 11(1), first subparagraph).

LMT batteries follow a separate paragraph with a different person doing the replacement: Article 11(5) requires replacement by an independent professional, not by the end-user (Article 11 on EUR-Lex). Removability is one of the product rules listed among the EU Battery Regulation requirements.

Article 11 at a Glance

The table lists the nine paragraphs of Article 11 with what each requires and the date from which it applies; seven run on the Article 96(2)(a) date.

Which Batteries and Products Are Covered?

Article 11 covers two of the five battery categories: portable batteries incorporated in products, which the end-user must be able to replace, and LMT batteries, which an independent professional must be able to replace. Every product that carries such a battery is in scope, whatever its type, unless a derogation applies.

A portable battery is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is no electric vehicle, LMT or SLI battery (Article 3(1), point (9)).

An LMT battery is sealed, weighs 25 kg or less and provides traction to wheeled vehicles powered by an electric motor alone or with human power (Article 3(1), point (11)).

SLI, industrial and electric vehicle batteries carry no Article 11 duty, whatever the product they power. The table matches each category to its Article 3(1) point, the paragraph of Article 11 that applies and the person who must be able to replace the battery.

Table 2: The five battery categories of Article 1(3); two of them carry an Article 11 duty.

Products That Are Themselves Portable Batteries

Rechargeable power banks, charging cases for wearables such as hearing aids and earbuds, and vehicle battery jump starters are themselves portable batteries, so the Commission guidelines treat Article 11 as not applicable to them. The guidelines (Commission Notice C/2026/5531, section 2) are not binding, but they set the Commission's reading of scope.

The product in these cases is the battery itself, so no appliance exists from which it would have to be removed. Such products follow the battery rules of the Regulation, such as labelling, safety and producer responsibility, rather than Article 11(1).

When Does the Replaceable Battery Rule Apply?

Article 11 applies from 18 February 2027 under Article 96(2)(a) of Regulation (EU) 2023/1542, while the Regulation itself has applied since 18 February 2024. No earlier date in 2025 or 2026 applies to the removability duty; the Regulation entered into force on 17 August 2023 (Article 96(1)).

Delegated Regulation (EU) 2026/1770 has been in force since 11 November 2026 and replaces the derogation list with which Article 11 will apply, so the content of Article 11(2) changes before the duty itself bites. Every other date of the act is collected in the EU Battery Regulation timeline.

The date attaches to placing the product on the market, because Article 11(1) and (5) address the person who places products incorporating the batteries on the market. Recital 11 states that batteries placed in stock in the Union by distributors before the date of application of a requirement do not need to meet that requirement.

What Readily Removable and Readily Replaceable Mean

A portable battery is readily removable when the end-user can take it out with commercially available tools, without specialised tools unless they are provided free of charge with the product, and without proprietary tools, thermal energy or solvents (Article 11(1), second subparagraph).

Heat and solvents are excluded outright, so a battery whose removal needs either fails the test.

Recital 38 defines commercially available tools as tools available on the market to all end-users without the need for them to provide evidence of any proprietary rights and that can be used with no restriction, except health and safety-related restrictions.

The Commission guidelines (C/2026/5531, section 2.1) map these classes to EN 45554:2020. Commercially available tools cover both basic tools or no tools and commercially available tools as that standard defines them. Specialised tools are product-group-specific tools not sold to the public and not patent-protected, and proprietary tools should not be needed at all.

Removal is only half of the test under Article 11. A battery is readily replaceable when, after removal, it can be substituted by another compatible battery without affecting the functioning, the performance or the safety of the appliance or the LMT (Article 11(6)).

Instructions and Safety Information Online

Products incorporating portable batteries must come with instructions and safety information on the use, removal and replacement of the batteries, also made available permanently online on a publicly available website in an easily understandable way (Article 11(1), third subparagraph). The duty sits in the same paragraph as the end-user removal test.

The online copy is permanent, so it outlives the sale of the product model. An end-user who replaces the battery years after purchase must still find the removal steps and the safety information, for the lifetime of the product that the first subparagraph protects.

LMT Batteries: Replacement by an Independent Professional

Article 11(5) requires LMT batteries, and the individual battery cells in the pack, to be readily removable and replaceable by an independent professional at any time during the lifetime of the product. The rule thus reaches below the pack level, while Article 11(1) for portable batteries stops at the entire battery.

The Regulation does not define "independent professional". The Commission guidelines (C/2026/5531, section 3.1) describe independent operators who have the technical competence and qualification to repair the product in which the battery is integrated, and who conduct their business on a commercial basis or in commercial premises, or both.

The readily replaceable test of Article 11(6) applies to the LMT as well: a compatible battery must work without affecting the functioning, performance or safety of the vehicle. A proposed change to the cell rule of Article 11(5) is set out in the final section.

The Eight Article 11(2) Derogations under Delegated Regulation (EU) 2026/1770

Delegated Regulation (EU) 2026/1770, adopted on 14 July 2026 and in force since 11 November 2026, replaces Article 11(2) with eight points, (a) to (h), for which the portable battery may be designed for replacement by independent professionals only instead of the end-user. The derogation shifts who replaces the battery; it does not remove the duty.

Seven points carry a safety condition: points (a) and (c) to (h) apply only where the derogation is required to ensure the safety of the user and the appliance. Point (b) applies without that condition, and point (d) for electric toys applies only until 31 July 2030 (Delegated Regulation (EU) 2026/1770 on EUR-Lex).

The original Article 11(2) of OJ L 191 had two points only: wet appliances without wearables, and professional medical imaging, radiotherapy and in vitro diagnostic devices.

For products placed on the market from 18 February 2027 the eight-point list applies, quoted here from the Official Journal text. Every adopted act is listed under battery regulation delegated acts.

How the Guidelines Read the Wet-Appliance Derogation

The Commission guidelines link the terms of point (a) to IEC 60529 ratings, splashing water to IPX4, water streams to IPX5 or IPX6 and water immersion to IPX7, and state that an IP rating alone is not sufficient to show that the derogation applies. The reading sits in C/2026/5531, section 3.2.1, and is not binding.

The guidelines name five indicators for point (a): the appliance is specifically designed for the wet environment; it operates there primarily, meaning for the majority of its active service; it is washable or rinseable; replacement by the end-user would compromise safety; and no redesign avoids the risk. The last two need evidence in the documentation.

The Article 11(3) Full Derogation for Continuous Power and Data Integrity

Article 11(3) lifts the removability and replaceability duty entirely where continuity of power supply is necessary and a permanent connection between the product and the battery is required for the safety of the user and the appliance, or, for products whose main function is to collect and supply data, for data integrity reasons. Unlike Article 11(2), no replacement route remains.

The table lists the guideline examples (C/2026/5531, sections 4.1 and 4.2) for each of the two reasons. They are guidance, not a list in the act: a product outside the table can qualify, and one inside it must still meet the condition of Article 11(3).

Smoke alarms appear here as a safety example under Article 11(3), with a battery of at least 10 years, not as a point of Article 11(2). Every product in the table still needs the permanent connection that Article 11(3) requires; a long battery life alone does not qualify it.

Spare Batteries and the Ban on Replacement-Blocking Software

Article 11(7) requires portable and LMT batteries to be available as spare parts of the equipment they power 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 for independent professionals and end-users.

The Commission guidelines (C/2026/5531, section 5.2) suggest delivery within five working days after receiving the order, by analogy with ecodesign implementing regulations. The same section states that Article 11(7) does not apply to products incorporating portable or LMT batteries placed on the market before 18 February 2027.

Article 11(8) bans software that impedes the replacement of a portable or LMT battery, or of their key components, with another compatible battery or key components. The ban complements Article 11(6): a battery that fits mechanically but is refused by the firmware is not readily replaceable in practice.

The guidelines (section 5.3) allow a software notice that a non-original battery is in use, provided it does not affect functionality or user experience. Parts pairing, which ties a battery to one device by serial number, is their example of impeding software.

Delegated Act, Guidelines and Derogation Calls: Status as of 13 November 2026

As of 13 November 2026, Article 11 rests on one adopted secondary act, Delegated Regulation (EU) 2026/1770, and on two non-binding Commission Notices, C/2025/214 of 10 January 2025 and its update C/2026/5531 of 22 October 2026.

Delegated Regulation (EU) 2026/1770 is based on the Article 11(4) empowerment and was adopted as Commission document C(2026)5031. Its draft, Ares(2026)4360577, published on 28 April 2026, drew 127 feedback responses. The updated guidelines appeared on the same day as the act (C/2026/5531 on EUR-Lex).

The list in Article 11(2) grew through a call for applications. The Commission invited applications for derogations before 30 April 2025, and that first call is closed. The guidelines (section 3.2.4) set a three-month period for submitting evidence in calls under Article 11(4).

The guidelines are adopted under Article 11(9) and are not binding: a market surveillance authority applies the Regulation, not the notice. Besides Delegated Regulation (EU) 2026/1770, the other acts adopted under the Regulation, Delegated Regulation (EU) 2025/606 and Implementing Regulation (EU) 2025/2289, concern recycling efficiency and reporting, not removability.

Who Carries the Removability Duty and How Compliance Is Shown

The removability duty falls on whoever places the finished product on the market: Article 11(1) and (5) address any natural or legal person that places on the market products incorporating portable or LMT batteries. Equipment makers and importers placing finished equipment on the EU market carry it, as set out for batteries in appliances.

Article 11 is outside both conformity lists of the battery: Article 5 makes Articles 6 to 10, 12, 13 and 14 a condition for placing a battery on the market, and the EU declaration of conformity covers the same articles (Article 18(1)). It is a product-design duty.

Reliance on a derogation is shown in the product's own documentation. The wet-appliance indicators of the guidelines expect evidence that end-user replacement would compromise safety and that no redesign avoids it, so the person placing the product on the market records the derogation point, the reason and the test results beforehand.

National law sets the penalties. In Germany, § 60(2) No. 1 of the Batterierecht-Durchführungsgesetz (BattDG, the battery implementing act) makes a breach of Article 11(1) or (5) an administrative offence, with a fine of up to EUR 10,000 under § 60(3) (§ 60 BattDG, as of 13 November 2026), as explained for the EU Battery Regulation in Germany.

How to Meet the Removability Requirements

Removability is met at the design stage, so the product file should show by 18 February 2027 which battery category the product carries, which paragraph of Article 11 applies and, where relevant, which derogation point and why. The seven steps below follow the order of the design work.

1. Confirm which battery category the product carries.
2. Check the Article 11(2) points and Article 11(3) examples, and record derogation evidence.
3. Test removal with commercially available tools only.
4. Publish the instructions and safety information online.
5. Plan spare batteries for five years after the last unit.
6. Remove software that blocks compatible batteries.
7. Check battery regulation enforcement and national penalties in every market.

The design duty is uniform across the EU because the Regulation is directly applicable, but enforcement and fines are national. A product sold in several member states therefore meets one design rule and faces as many penalty regimes as markets.

Need help with battery removability? The full sequence by role and category is set out under the battery regulation compliance programme.

What Changes Next: The Directive Transition and the Proposed LMT Module Rule

Until 18 February 2027, Article 11 of Directive 2006/66/EC continues to apply under Article 95(a) of the Regulation, although the Directive was otherwise repealed with effect from 18 August 2025. The transition rules of the repealed Batteries Directive 2006/66/EC are explained separately.

From 18 February 2027, Article 11 of the Regulation takes over, with its tool test, its derogation list, its spare battery period and its software ban. Products placed on the market from that date follow the Regulation alone, and the Directive provision has no further effect on them.

The Commission proposal COM(2025) 981 of 10 December 2025 (procedure 2025/0397(COD)) would replace "individual battery cells" with "individual battery modules" in Article 11(5). LMT batteries would then have to be replaceable by an independent professional at module level rather than cell level (COM(2025) 981 on EUR-Lex).

The proposal is pending: as of 13 November 2026 it is at the stage "Awaiting committee decision" in the Parliament's ENVI committee, with an indicative plenary on 14 December 2026 and no Council position listed. The adopted text of Article 11(5) keeps the cell level, as tracked under battery regulation amendments.

Removability Questions

Five questions recur about the EU replaceable battery rule.

Does the EU require removable batteries in smartphones?

Article 11 names no product types: it applies to every product incorporating a portable battery from 18 February 2027, unless a derogation applies. For smartphones and slate tablets, the Commission guidelines (C/2025/214) state that the battery rules of the ecodesign Regulation (EU) 2023/1670 prevail over Article 11.

Are replaceable batteries mandatory from 2027?

Yes: Article 11 applies from 18 February 2027 (Article 96(2)(a)) to products incorporating portable or LMT batteries that are placed on the market from that date. Before that date, Article 11 of the repealed Batteries Directive still applies under Article 95(a).

Can a battery still be glued into a product?

Not where removal would need thermal energy or solvents: Article 11(1), second subparagraph, excludes both, unless the product falls under an Article 11(2) or 11(3) derogation. Under a point of Article 11(2), an independent professional must still be able to replace the battery.

Do products placed on the market before 18 February 2027 need spare batteries?

No: the Commission guidelines state that Article 11(7) does not apply to products placed on the market before 18 February 2027. The guidelines are not binding, so the reading reflects the Commission's interpretation, not a provision of the Regulation itself.

Does Article 11 cover EV, SLI or industrial batteries?

No: Article 11 covers portable batteries in products and LMT batteries only; EV, SLI and industrial batteries carry no removability or replaceability duty under it. Their design rules come from other articles of the Regulation, such as safety and performance.