Update on the removability and replaceability of batteries (Art. 11 Battery Regulation)
The European Commission has published a draft delegated act concerning the requirements for the removability and replaceability of batteries (Art. 11 Battery Regulation). Feedback can be submitted until 26 May 2026.
What does Art. 11 Battery Regulation regulate?
Art. 11 Battery Regulation contains various provisions on the removability and replaceability of portable and LMT batteries incorporated into products. In particular, portable batteries incorporated into products must, as a general principle, be easily removable and replaceable by the end user throughout the lifetime of the product (para. 1, subpara. 1). However, certain products benefit from facilitations (para. 2) and exemptions (para. 3).
Art. 11 Battery Regulation will apply from 18 February 2027. Due to typically long product design and development cycles, the requirements of Art. 11 are already highly relevant in practice.
Which provision of Art. 11 Battery Regulation is addressed by the current draft?
The draft concerns the facilitation under paragraph 2. This provision allows that, for certain products, easy removability and replaceability by the end user is not required, provided that removal and replacement can be carried out by independent professionals.
Pursuant to paragraph 4, the Commission is empowered to adopt delegated acts to extend the list of products covered by this facilitation. A draft of such a delegated act has now been published.
Which products are covered by the current draft?
The current draft specifically covers the following product groups:
- certain wearables
- (temporarily) electric toys powered by rechargeable batteries
- wireless thermometer probes intended for food contact
- certain products for use in potentially explosive atmospheres
- on-body delivery systems specifically designed for the subcutaneous administration of medicinal products
- telematics devices intended for roof mounted installation on agricultural and construction machinery
How can feedback be submitted?
Until 26 May 2026, feedback on the draft can be submitted via the European Commission’s portal. The draft is also available there.
