Updates on Article 11 of the Battery Regulation
The requirements set out in Article 11 of the Battery Regulation regarding the removability and replaceability of portable batteries and LMT batteries will apply from 18 February 2027. Below, we provide you with information on the latest developments.
What is the current status of the delegated act on simplifications?
Article 11(2) of the Battery Regulation provides for a derogation from the requirements concerning the removability and replaceability of batteries for certain products. For such products, it is not necessary for batteries to be removable and replaceable by end-users. Instead, it is sufficient that the incorporated batteries can be removed and replaced by independent professionals.
In our blog post of April 2026, we informed you about the draft delegated act intended to supplement the list of products referred to in Article 11(2) of the Battery Regulation. The European Commission has now adopted this delegated act.
Which additional products will benefit from the derogation?
The delegated act supplements the existing list of products set out in Article 11(2) of the Battery Regulation by adding six further product categories. As a result, the derogation will apply to the following product categories:
- Products specifically designed for use in wet environments
- professional medical imaging and radiotherapy devices and in vitro diagnostic medical devices
- certain wearables
- (temporarily) electric toys containing rechargeable batteries
- wireless thermometer probes specifically designed for food contact during food preparation processes
- products falling within the scope of the ATEX-Directive
- on-body delivery systems specifically designed for the subcutaneous administration of medicinal products
- telematics devices intended for roof mounted installation in agricultural and construction machinery
What are the next steps in the process?
The next step in the procedure is for the delegated act to be submitted to the European Parliament and the Council for scrutiny. If neither institution raises any objections within the prescribed time limit, the act will be published in the Official Journal of the European Union, will then enter into force, and will supplement the provisions set out in Article 11(2) of the Battery Regulation.
What is the current situation regarding the Commission’s guidelines?
To support the harmonised application of the requirements regarding the removability and replaceability of portable batteries and low-voltage batteries, the European Commission published guidelines in January 2025. We have already covered these in an earlier Blog post.
At the same time as the delegated act was adopted, the Commission has now published an updated version of the guidelines. The updated version contains additions and further details. The vast majority of the product groups added by the delegated act are not yet covered in the current version of the guidelines.
