# EU replaceable battery law: what changes for your products on 18 February 2027 > Canonical: https://shippeu.com/resources/blog/replaceable-batteries > Published: 11 November 2026 · Last source review: 10 November 2026 · ShippEU From 18 February 2027, the EU replaceable battery law, Article 11 of Regulation (EU) 2023/1542, requires a product placed on the EU market with a portable battery inside to let its user remove and replace that battery with tools anyone can buy. The duty sits with whoever places the product on the market: for goods made outside the EU, usually the importer. ## In short - From **18 February 2027**, a portable battery built into a product placed on the EU market must be removable and replaceable by its user, at any time in the product's life. - Removable means with tools anyone can buy: no proprietary tool, no heat, no solvent. A specialised tool is allowed only if it comes free with the product. - The duty falls on whoever places the product on the market, the first time it is made available in the EU. - Eight groups of products may reserve the battery for independent repairers, under conditions. Six of them come from a delegated regulation in force from 11 November 2026. - Spare batteries stay on sale for five years after the last unit of a model, and software may not block a compatible replacement. ## Key facts - **18 Feb 2027** — Article 11 applies (Regulation (EU) 2023/1542, Article 96(2)(a)) - **5 years** — Spare batteries on sale after the last unit of a model (Article 11(7)) - **8** — Product groups that may reserve the battery for independent professionals (Article 11(2), as replaced from 11 Nov 2026) - **31 Jul 2030** — End of the exemption for electric toys (Delegated Regulation (EU) 2026/1770) ## What does the EU replaceable battery law require? Article 11 of [Regulation (EU) 2023/1542](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A02023R1542-20260813) requires any portable battery built into a product to be **readily removable and replaceable by the end-user** at any time during the product's lifetime. It applies from 18 February 2027 (Article 96(2)(a)). The rule covers the whole battery, not the cells inside it. > Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product. That obligation shall only apply to entire batteries and not to individual cells or other parts included in such batteries. > > Regulation (EU) 2023/1542, Article 11(1), https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A02023R1542-20260813 ### Removable with tools anyone can buy The regulation counts a battery as readily removable when it comes out with commercially available tools. Proprietary tools, heat and solvents are excluded. A specialised tool is acceptable only if it ships free of charge with the product. > A portable battery shall be considered readily removable by the end-user where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product. > > Regulation (EU) 2023/1542, Article 11(1), second subparagraph, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A02023R1542-20260813 The Commission's [guidelines on Article 11](https://eur-lex.europa.eu/eli/C/2025/214/oj) read commercially available tools through the repair standard EN 45554:2020, and the end-user as an adult with no particular experience or qualification. The guidelines are the Commission's reading, not law: the Court of Justice has the last word. ### Replaceable, documented, and not blocked by software Readily replaceable means a compatible battery can take the place of the one removed without affecting how the product works, performs or stays safe (Article 11(6)). The product comes with instructions and safety information on using, removing and replacing the battery, and the same information stays online, on a public website, for good. Software may not be used to stop a compatible replacement (Article 11(8)): the Commission names parts-pairing as the practice it means. ### Spare batteries for five years Batteries remain available as spare parts for at least five years after the last unit of the model is placed on the market, at a reasonable and non-discriminatory price for independent repairers and end-users (Article 11(7)). The Commission's guidelines add that this does not apply to products placed on the market before 18 February 2027. ### E-bikes and e-scooters: LMT batteries Light means of transport (LMT) batteries, sealed batteries of up to 25 kg that power e-bikes, e-scooters and similar vehicles, follow a different rule. The battery and each of its cells must be replaceable by an independent professional: a repairer with the competence to do it, working on a commercial basis (Article 11(5)). ## When does it apply? Three dates frame the rule: the delegated regulation that rewrote the exemptions, the day Article 11 applies, and the end of the exemption for toys. - **11 November 2026**: Delegated Regulation (EU) 2026/1770 enters into force. Six product groups join the list of Article 11(2), and wet appliances now include wearables. - **18 February 2027**: Article 11 applies. Removability by the user, instructions online, spare batteries for five years, no software lock. - **31 July 2030**: Last day of the exemption for electric toys. From 1 August 2030, the toy safety regulation, (EU) 2025/2509, sets its own battery rules for toys. ## Which products does it cover? Every product placed on the EU market with a **portable battery** inside: a sealed battery of 5 kg or less that is not an industrial, electric-vehicle, LMT or starter battery (Article 3(9)). Earbuds, smartwatches, speakers, toothbrushes, toys and e-cigarettes all qualify. The Commission's guidelines name greeting cards, smart textiles, wearables and electronic cigarettes among the products concerned. Smartphones and tablets follow their own ecodesign rules, Regulation (EU) 2023/1670. The Commission's guidelines say its battery requirements prevail over Article 11 for those products. Article 11 is a design rule. It does not replace the producer registration for [battery EPR](https://shippeu.com/streams/batteries), which the same regulation organises country by country, nor the WEEE file of an electrical product. A product with a battery inside usually owes all three: see [electronics and batteries](https://shippeu.com/solutions/electronics-batteries). ## Who has to comply: the brand, the importer or the marketplace? Article 11 puts the duty on the natural or legal person that **places the product on the market**, which the regulation defines as the first making available on the EU market (Article 3(16)). When the brand manufactures in the EU, that is the brand. When the product is made outside the EU, it is usually the importer: the first business that supplies it in the EU. If you sell from outside the EU, each unit still has a first supply in the EU, and Article 11 is checked against that unit. Ask your manufacturer now how the battery comes out, and for the documents that show it. Article 11 does not name online marketplaces. The obligation stays with the operator who places the product on the market. ## Which products are exempt? There are two kinds of exemption, and both come with conditions. Together with the general rule, they give three answers to the same question. **Who must be able to take the battery out** - **The end-user** (Article 11(1)): The general rule for portable batteries; Tools anyone can buy, no heat, no solvent; From 18 February 2027 - **An independent professional** (Article 11(2) and 11(5)): Eight product groups, under conditions; LMT batteries and their cells; A repairer working on a commercial basis - **No one: the duty is lifted** (Article 11(3)): Uninterrupted power needed for safety; Collecting data as the main function; Pacemakers, hearing aids, ten-year smoke alarms ### Battery reserved for independent professionals Article 11(2) lists products whose battery may be designed for removal by an independent professional instead of the user. [Delegated Regulation (EU) 2026/1770](https://eur-lex.europa.eu/eli/reg_del/2026/1770/oj/eng), in force from 11 November 2026, rewrote that list. It now holds eight groups. - **Wet appliances** (Wearables added): Designed to work mainly under splashing water, water streams or immersion, and meant to be washed or rinsed. The Commission reads those conditions as IPX4, IPX5 or IPX6, and IPX7, and cites toothbrushes, shavers, hair clippers and epilators. - **Medical devices**: Professional medical imaging and radiotherapy devices, and in vitro diagnostic devices. The only group without the safety condition. - **Wearables** (New): When user access to the battery would compromise safety, durability or water resistance, and the device is too small for a safe replacement or relies on a sealed enclosure. Smartwatches, fitness trackers and smart glasses are the delegated regulation's examples of wearables. - **Electric toys** (Until 31 Jul 2030): With rechargeable batteries, when the toy's nature or size makes it necessary for its safety. - **Food thermometer probes** (New): Wireless probes designed for food contact while cooking. - **Explosive atmospheres** (New): Equipment for potentially explosive atmospheres, within the scope of Directive 2014/34/EU. - **Medicine delivery** (New): On-body systems designed to inject medicinal products under the skin. - **Machinery telematics** (New): Telematics boxes mounted on the roofs of agricultural and construction machinery, exposed to vibration, dust and water. Every group except the medical one applies only where the exemption is required for the safety of the user and the appliance. For a wet appliance, the Commission also expects the product documentation to show, when the product is placed on the market, that it could not be redesigned. ### No removability duty at all Article 11(3) lifts the obligation in two cases: when the product needs an uninterrupted power supply and a permanent connection to its battery for safety, and when its main function is to collect and supply data and removal would put that data at risk. The Commission's examples include pacemakers and other life-sustaining devices, hearing aids, smoke alarms built to run ten years on a battery of the same life, professional weather stations, backup batteries for computer memory, and payment terminals. A data function added to another main function does not qualify. ## What about stock already in the EU? The obligation attaches to placing on the market, the first time a unit is made available in the EU. The Commission's guidelines confirm it for spare batteries only, which are not owed for products placed on the market before 18 February 2027. > **Our reading:** The rule applies unit by unit. A unit first made available in the EU before 18 February 2027 is not caught; one first made available on or after that date is, even if the model is the same. If you rely on that reading for a model that doesn't comply, keep the proof of when each batch was first supplied in the EU, and plan the last shipments before the date. ## What to check in your catalogue before February Start with one product: four questions at most tell you which of the three answers applies to it. _An interactive check sits here on the page: https://shippeu.com/resources/blog/replaceable-batteries#tool-replaceable-battery-check_ Then go through the list below for every product with a battery inside, with the manufacturer's documents in hand. **Before 18 February 2027, for each product with a battery inside** - [ ] **The battery comes out** with tools anyone can buy, without heat or solvent. A specialised tool, if one is needed, ships free in the box. - [ ] **A compatible battery** works once fitted, and no software blocks it. - [ ] **An exemption**, if you rely on one, meets every condition of its group, and the product file says why safety requires it. - [ ] **Instructions and safety information** come with the product and stay online, on a public page. - [ ] **Spare batteries** stay on sale for five years after the last unit, at a reasonable price. - [ ] **The dates**: when each batch is first supplied in the EU, against 18 February 2027. Then check the files that sit beside this rule: the [battery EPR](https://shippeu.com/streams/batteries) registration in each country you sell to, and WEEE for the electrical product. The [scope check](https://shippeu.com/start) lists them by country in six questions. ## FAQ **Do wireless earbuds need a replaceable battery from 2027?** The rule applies to them unless an exemption fits. Earbuds are worn on the body, so the new wearables group can cover them: when user access to the battery would compromise their safety, durability or water resistance, when they are too small for a safe replacement or rely on a sealed enclosure, and only where safety requires it. The text does not name earbuds: document the reasons model by model. **Is a glued-in battery still allowed?** Article 11 does not mention glue. It rules out removal that needs heat, solvents or a proprietary tool, so a battery that only comes out once its adhesive is heated or dissolved does not pass. **Does this replace battery EPR registration?** No. Article 11 is a rule about how the product is designed. Registering as a battery producer, declaring quantities and financing collection are separate obligations of the same regulation, handled country by country: see [what battery EPR involves](https://shippeu.com/streams/batteries). **Are smartphones covered?** Smartphones and tablets follow their own ecodesign rules, Regulation (EU) 2023/1670. The Commission's guidelines say its battery requirements prevail over Article 11 for those products. ## Sources - Regulation (EU) 2023/1542 on batteries and waste batteries, consolidated text of 13 August 2026 — https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A02023R1542-20260813 - Commission Delegated Regulation (EU) 2026/1770 on derogations for the removability and replaceability of portable batteries — https://eur-lex.europa.eu/eli/reg_del/2026/1770/oj/eng - Commission guidelines on the removability and replaceability of portable and LMT batteries (C/2025/214) — https://eur-lex.europa.eu/eli/C/2025/214/oj - Delegated regulation for the removability and replaceability of portable batteries — https://environment.ec.europa.eu/publications/delegated-regulation-removability-and-replaceability-portable-batteries_en ShippEU is a private service. It is not an authority, a register or a collective scheme. Figures come from published guidance; rules change. The scope check at https://shippeu.com/start is reviewed by a person before any quote.