On 18 February 2027, Article 11 of Regulation (EU) 2023/1542 will introduce mandatory removability and replaceability rules for products with portable batteries or LMT (light means of transport) batteries. Any affected product placed on the EU market on or after this date must comply with the new requirements. With the compliance deadline only a few months away, high demand for conformity assessment and testing services for re-certifying products is expected to slow time to market.
The primary goals of Article 11 are to:
For products with portable batteries, the battery must be replaceable by an ordinary end-user during the product’s lifetime. The use of specialised tools must not be required unless provided free with the product. Also, the replacement process must not require heat guns, soldering irons or chemical solvents, and disassembly must not cause permanent damage to the product or battery. LMT batteries must be removable and replaceable by independent repair professionals or end-users where applicable, without specialised equipment unless provided.
Article 11 contains both partial derogations and full exemptions from the general requirement that portable batteries must be removable and replaceable. However, it’s important to remember that the applicability of an exemption must always be assessed against the specific conditions of Article 11, as a product category does not automatically qualify for a derogation or exemption.
Partial derogations include some product categories where portable batteries may only be removable and replaceable by independent professionals, rather than end-users. This includes appliances designed to operate primarily in environments regularly exposed to splashing water, water jets or immersion, or those that are intended to be washable or rinseable, for example some waterproof electric toothbrushes, waterproof shavers or diving computers. Some professional medical imaging and radiotherapy devices, as well as certain in-vitro diagnostic medical devices, may also have partial derogations. Examples include MRI systems, CT scanners or laboratory diagnostic analysers.
Full exemptions apply where there is a requirement for continuity of power and a permanent connection between the product and the battery, to ensure the safety of the user and appliance. Examples include permanently powered safety devices or emergency systems. Products whose main function is to collect and supply data, where a permanent battery connection is necessary to preserve data integrity, may also be exempted. Examples include data loggers, metering devices or industrial monitoring equipment.
For many, compliance with Article 11 will require enclosure and structural redesign, such as replacing adhesives with screws, latches or gaskets that will increase product thickness, weight and assembly complexity. For products that must comply with waterproofing and IP rating requirements, adding consumer-accessible features will be a design challenge. Battery compartments must also be designed so end-users do not accidentally puncture lithium pouch cells, short-circuit terminals or cause thermal dissipation.
Article 11 requires spare parts and repair channels to be established, including inventory mechanisms to supply replacement batteries and key components to end-users and independent repair operators for at least five years post-market. This creates additional warehousing needs and inventory costs. Embedded software and battery management systems (BMS) must also be redesigned to remove software locks while ensuring non-OEM batteries still operate safely.
A common misconception about the EU Battery Regulation requirements in 2027 is that smartphones will have to return to old designs, with removable back covers and snap-in batteries. However, smartphones are subject to battery replaceability requirements under the Ecodesign Regulation (EU) 2023/1670, whose requirements take precedence over those of Article 11. While smartphone manufacturers do not have to revert to early-generation phone designs, they must comply with the dedicated repairability and battery replacement requirements applicable to smartphones under the Ecodesign framework.
Economic operators should complete a comprehensive audit of the entire existing and upcoming product portfolio against Article 11 criteria relating to replaceable and removable batteries. This will determine which products require redesign and which qualify for derogations. Enclosures will need redesigning so that glue and solvents are eliminated, to ensure they can accommodate standard mechanical fasteners and that batteries can be swapped with standard off-the-shelf tools.
Technical documentation will also require updating, as it must include clear, user-friendly removal/replacement instructions and safety guides hosted online. For any products exempted under Article 11, formal technical files must be prepared to submit derogation requests.
TÜV SÜD’s extensive technical verification and testing services help affected companies comply with Article 11’s battery removability and replaceability requirements and identify/assess the suitable exemptions. From mechanical design evaluations and safety testing to software compliance assessments, we help ensure your portable and LMT battery-powered products meet every standard before entering the EU market. Our certification services are delivered by TÜV SÜD’s recognised Certification Bodies in an independent and impartial manner separate from our advisory and testing services. Find out more about our battery testing and EU Battery Regulation services.
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