The European Commission has opened a public consultation on new exceptions to the rules that will require built-in portable batteries in products sold in the European Union to be more easily removable and replaceable. The general rule, included in the Battery Regulation, aims to extend the lifespan of devices, improve repairability, and facilitate recycling. However, Brussels recognizes that not all products can be treated the same way.
The consultation, open until May 26, proposes adding six new categories of products to the list of exceptions. Among the examples cited by the Commission are wearable devices such as smartwatches and activity bands, electric toys, and equipment covered by the ATEX Directive, used in explosive atmospheres, such as motors, sensors, pumps, or explosion-proof forklifts.
The General Rule: Batteries that the User Can Change
Regulation (EU) 2023/1542 on batteries came into force in August 2023 and is part of the European strategy to reduce the environmental impact of batteries throughout their lifecycle. One of its most discussed measures is the obligation that portable batteries integrated into products can be removed and replaced by the end user during the device’s lifetime. This requirement will begin to be enforced on February 18, 2027.
The idea is to address a known issue: many products continue to function properly but become obsolete when their batteries lose capacity. In older mobiles, remote controls, small appliances, headphones, toys, or connected devices, a degraded battery can turn a reparable product into premature waste.
The regulation does not necessarily require returning to the detachable backs of twenty years ago. It allows the battery to be removed with tools available on the market, provided that proprietary tools, heat, solvents, or procedures that damage the product or the battery are not needed. It also obliges manufacturers to provide instructions and facilitate access to spare parts for a reasonable period.
For repair enthusiasts and advocates of the right to repair, this is one of the most important aspects of the new regulation. An accessible battery reduces repair costs, prevents complete replacements, and can enable independent repair shops to compete with official services. For manufacturers, however, it presents challenges related to design, safety, waterproofing, size, certification, and warranty.
Why Brussels Wants New Exceptions
The Commission already considers partial exceptions for certain products. In some medical devices, products used in humid environments such as electric toothbrushes or oral irrigators, and other equipment where safety can be compromised, the battery does not need to be replaceable by the average user. In these cases, it is sufficient that an independent professional can remove and replace it.
The new consultation aims to extend this logic to products where easily accessible batteries could pose more risks than benefits. For example, in a smartwatch, opening the device could affect water resistance, health sensors, internal adhesives, or the very compact design. In electric toys, concerns may relate more to child safety, accidental access to internal components, or improper use of replacement batteries. In ATEX equipment, the margin for error is even lower: these are devices designed to operate in environments where a spark, a leak, or improper handling could have serious consequences.
This proposal does not mean that these products are free from all obligations. The logic behind partial exemptions is that the battery can be removed and replaced by independent professionals, not necessarily by any consumer. This distinction is important: Brussels is not abandoning repair, but shifting it toward qualified technicians when safety or design reasons justify it.
The Commission states that it has worked with consumer associations, industry, Member States, and external experts to evaluate the requests received following a call launched in 2025. It also claims to have balanced the interests of consumers, independent repairers, product manufacturers, battery producers, and the recycling sector.
Balancing Repair and Risk Prevention
The debate is sensitive because it pits two legitimate objectives against each other. On one side, Europe wants more durable products, less waste, and increased repairability. On the other, small lithium-ion batteries can cause fires if mishandled, punctured, crushed, or damaged during waste treatment processes. The Commission itself warns that poorly discarded small lithium batteries are causing an increasing number of fires at treatment facilities.
This risk does not negate the right to repair but underscores the need for careful design. A user-replaceable battery must be accessible, safe, identifiable, and accompanied by clear instructions. If the process involves removing a screen with heat, cutting adhesives near sensitive cells, or handling sealed components, home repairs may be ill-advised.
Manufacturers will likely argue that certain categories require broad exceptions to ensure safety, durability, or water resistance. Independent repairers and consumer organizations will monitor to ensure these exceptions do not become backdoors to keep products sealed without sound technical reasons.
The key will be how the delegated act is written. If exceptions are too broad, they could weaken one of the most ambitious measures of the regulation. If too narrow, they might force unrealistic redesigns or even introduce risks in sensitive products. Brussels will need to define precise criteria to prevent terms like “safety” or “compact design” from being overused as generic excuses.
For consumers, the impact may become visible in the coming years. Some products will need to be easier to open and maintain. Others, if the proposal succeeds, may still require professional intervention to replace the battery. The differences should be clearly explained in the product documentation, after-sales service, and in the availability of spare parts.
The core issue goes beyond a simple battery or small component. The battery has become one of the key points where the actual lifespan of many devices is determined. The European Union aims to stop it from being a hidden, irreplaceable component, while acknowledging that not all devices can be opened in the same way. The outcome of this consultation will indicate how far the right to repair extends to small, connected, and increasingly sealed products.
Frequently Asked Questions
What is the European Commission currently consulting on?
The Commission has launched a public consultation on new exceptions to the rules regarding the removal and replacement of portable batteries in products sold in the EU. The comment deadline is May 26.
Will the EU require all batteries to be changed by the user?
The general rule is that portable batteries integrated into products should be removable and replaceable by the end user starting February 18, 2027, but there are exceptions for safety or design reasons.
Which products might receive new exceptions?
The Commission mentions, among others, smartwatches, activity trackers, electric toys, and ATEX equipment used in explosive environments.
Does this mean those products won’t be repairable?
Not necessarily. In many exceptions, the battery would not need to be user-replaceable but could be serviced by independent professionals with appropriate tools.