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More exceptions for battery replaceability proposed in Europe

Written by Nemko | October 1, 2026

                                                                                                                                                                              

The European Commission has proposed to exempt additional products from the requirements on the removability and replaceability of portable batteries by consumers.

The existing battery regulations, applicable to portable batteries regarding the ability of consumers to remove and replace batteries in certain products, stipulate that such batteries must generally be removable and replaceable by consumers. The intent of this requirement is to facilitate a longer useful product life and easier recycling of used batteries.

However, certain products are exempt from these regulations in cases when replacing a battery could pose safety risks to consumers, or the technical complexity of a battery-powered device makes consumer access to the battery compartment difficult.

Existing exemptions for consumer access include devices that can be exposed to water or that could expose 
children to unnecessary risks, as well as equipment used in hazardous industrial environments. It is now proposed to add a number of products to the list of those exempt from consumer access requirements, including the following:

  • Appliances, including wearable devices designed for use in environments where exposure to water is possible;
  • Professional medical imaging and radiotherapy devices;
  • Wearable devices for which consumer access to the battery could compromise safety;
  • Wireless thermometer probes designed for contact with food products;
  • On-body delivery systems used for delivery of subcutaneous medicinal products;
  • Certain electric toys that incorporate rechargeable batteries.

The EU Parliament and Council now have two months to consider any objections to the proposed changes. If none are offered, a so call Delegated Regulation about this will enter into force 20 days after its publication in the Official Journal of the European Union.

More information about this topic may be seen here.

(This article is based on an article in the InCompliance magazine; edited by T.Sollie)