Batteries: end-user removability on 18 February 2027

Author Hugues Orgitello Last updated 22 August 2026 ~6 min read

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Regulation (EU) 2023/1542 has applied since 18 February 2024, but its Article 11 was deferred: Article 96(2), point (a), makes it applicable on 18 February 2027. From that date, any product incorporating a portable battery must let the end-user remove and replace that battery readily. The same day, Article 13(6) requires a QR code on every battery, and Article 77 makes the battery passport mandatory for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries.

In short:

Article 11 applies on 18 February 2027. The legal test is the use of "commercially available tools", not "basic" tools.
Same date: a QR code on all batteries, and a battery passport for LMT, industrial above 2 kWh and electric vehicle batteries (Article 77).
Commission Delegated Regulation C(2026) 5031 final of 14 July 2026 rewrites the derogation list and adds six categories, wearable devices among them; it has not yet been published in the Official Journal.
Spare parts: five years minimum after the last unit of the equipment model is placed on the market, at a reasonable and non-discriminatory price.
The only full exemption requires data collection to be the product's main function and data integrity to be at stake.

What Article 11 actually says

The official heading is "Removability and replaceability of portable batteries and LMT batteries". The battery must be "readily removable and replaceable by the end-user at any time during the lifetime of the product", and the obligation covers entire batteries, not individual cells. The test: it comes out using commercially available tools, without specialised tools (unless supplied free of charge with the product), without proprietary tools, thermal energy or solvents.

Two phrasings are widely repeated but appear nowhere in the Regulation. It does not say "basic tools": that category comes from EN 45554:2020, and the Article 11 concept is broader. Nor does it say "without damaging the product": Article 11(6) requires that the replacement battery work "without affecting the functioning, the performance or the safety" of the appliance.

The remainder shapes the technical file: instructions and safety information supplied with the product and made permanently available online on a publicly available website; LMT batteries removable by an independent professional, cells included; availability as a spare part for at least five years; no software impeding replacement, all without prejudice to stricter WEEE rules.

Derogations: two categories today, eight tomorrow

Two regimes are routinely conflated. Article 11(2) is a partial derogation: the battery may be designed to be removable only by independent professionals. In the consolidated text of 31 July 2025 it contains just two points, washable or rinseable appliances and professional medical imaging, radiotherapy and in vitro diagnostic devices. Article 11(3) is the only full exemption.

On 14 July 2026 the Commission adopted Delegated Regulation C(2026) 5031 final, the first act adopted under Article 11(4). Its Article 1 replaces paragraph 2 with eight points.

Point	Category
(a)	Washable or rinseable appliances, wearable devices included
(b)	Professional imaging and radiotherapy, in vitro diagnostics
(c)	Wearable devices whose safety, durability or water resistance may be compromised by user access to the battery, and which are too small for safe replacement or rely on a compact sealed enclosure
(d)	Electric toys with rechargeable batteries, until 31 July 2030
(e)	Wireless thermometer probes for food contact
(f)	Products within the scope of Directive 2014/34/EU (ATEX)
(g)	On-body systems for subcutaneous administration of medicinal products
(h)	Roof-mounted telematics for agricultural and construction machinery

Except at point (b), each derogation applies only where it is required to ensure the safety of the user and the appliance. The act's status warrants caution: no number has been assigned to it, Article 89(6) opens a three-month objection period extendable by two, and entry into force follows twenty days after publication in the Official Journal. Designing on the strength of a derogation that is not yet law is a bet.

Enclosure, fasteners, spare parts

Commission guidelines C(2026) 5032 final, adopted the same day and not legally binding, are an updated version of Commission Notice C/2025/214 of 10 January 2025; like the delegated act, they have not yet been published in the Official Journal. They define the end-user as "a person having attained the age of majority without any specific experience or related qualifications".

Ingress protection. The wet-appliance derogation rests on five cumulative indicators, including documented evidence that end-user removal would compromise safety and that no redesign is possible with currently available technology. IP ratings under IEC 60529 are an indicative guide, but are not sufficient on their own.

Fasteners. Where disassembly needs non-reusable fasteners, those fasteners must also be available as spare parts. On lead times, the Commission points to comparable ecodesign regulations, which require delivery within five working days.

Adhesives. They are not banned by name, but relying on thermal energy or solvents to disassemble the product is: bonds that release only through heat or dissolution are therefore out.

Software. Parts-pairing is named as an example of impeded replacement.

Two limits on scope: for smartphones and tablets covered by Regulation (EU) 2023/1670, Annex II of that text prevails; and a product whose primary function is to power other products is itself a portable battery, outside Article 11.

IoT: the data-integrity exemption is narrow

For a connected device, Article 11(3) is the obvious way out, and the guidelines largely close it. Qualifying cases include professional weather stations, temperature sensors critical to the transport of sensitive goods, and batteries powering volatile memory.

Two exclusions deserve a line in the design review. A product that collects data in addition to its main function has no claim to the exemption; nor does one whose main function it is but which carries no risk of data integrity loss, because it holds non-volatile memory.

Battery passport and QR code

From 18 February 2027 every LMT, industrial above 2 kWh or electric vehicle battery placed on the market or put into service has a battery passport, split across three access tiers: public, restricted to notified bodies and authorities, and restricted to persons with a legitimate interest. Article 77(9) sets 18 August 2026 as the date by which the Commission is to adopt implementing acts defining that last category. The passport opens through a QR code tied to a unique identifier complying with the ISO/IEC 15459 series, and Article 78 requires free access and interoperability with other digital product passports.

Consumer electronics is not off the hook: the QR code applies to all batteries, portable ones included. For those without a passport it gives access to the labelling information, the declaration of conformity, the due diligence report and the waste-battery information, printed or engraved visibly, legibly and indelibly on the battery, failing which on the packaging.

Regulation (EU) 2023/1542 timeline

Date	Milestone	Basis
17 August 2023	Entry into force	Article 96(1)
18 February 2024	General application	Article 96(2)
18 August 2024	Article 17 and Chapter VI	Article 96(2)(b)
18 August 2025	Chapter VIII; Directive 2006/66/EC repealed, except its Article 11	Articles 95 and 96
18 August 2026	Labelling, or 18 months after the implementing act	Article 13(1) to (3)
18 February 2027	Article 11; QR code; battery passport	Articles 96, 13 and 77
18 August 2027	Battery due diligence	Art. 48, as amended by Regulation (EU) 2025/1561
18 August 2028	Recycled content documentation, or 24 months after the delegated act	Art. 8(1)
18 August 2031	16 % cobalt, 85 % lead, 6 % lithium, 6 % nickel	Article 8(2)
18 August 2033	Recycled content extended to LMT batteries	Article 8(1)
18 August 2036	26 % cobalt, 85 % lead, 12 % lithium, 15 % nickel	Article 8(3)

The Article 7 carbon footprint dates remain conditional on the entry into force of the corresponding acts.

What to do

Settle the mechanical architecture early: a battery hatch, reusable fasteners and the absence of thermal bonding are decided before tooling freeze.
Do not assume a derogation: those in paragraph 2 merely move the operation to an independent professional, and the six new ones are not yet law.
Open the spare-part line for five years after the last unit of the model, non-reusable fasteners included, and publish the instructions online.