From February 2027, built-in batteries must be removable by the user. What does that mean for a product made in China?
From 18 February 2027, a product with a portable battery that is placed on the EU market must let its user take the battery out and put a new one in. The rule is Article 11 of the EU Batteries Regulation (EU) 2023/1542. For a product designed in China with a battery that only comes out with heat, solvents or a special tool, this is a change to the housing and the production line, not to the paperwork.
What the rule asks
The battery must be readily removable and replaceable by the end-user at any time during the lifetime of the product. The requirement covers the battery as a whole, not its individual cells.
| question | what the rule says |
|---|---|
| with which tools? | commercially available tools, such as a normal screwdriver; a specialised tool only if it is supplied free of charge with the product; never proprietary tools, heat or solvents |
| how? (guidance) | without damaging the battery or the product |
| by whom? (guidance) | an adult without specific experience in removing batteries |
| for how long? | spare batteries available for at least five years after the last unit of the model is placed on the market, at a reasonable and non-discriminatory price |
| with what help? | instructions and safety information for removal and replacement, with the product and permanently online |
| and software? | software may not be used to block a replacement battery |
The rows marked "(guidance)" come from the European Commission's guidelines on Article 11; the others are in the Regulation itself. A battery that only comes out with heat, solvents or a proprietary tool doesn't meet the rule, which rules out most glued or soldered cells.
Who the rule falls on
The obligation sits with whoever places the product on the EU market; for a product made in China, typically the EU importer or the brand that sells it under its own name. The date that counts is the date the product is placed on the market, not the date it was designed. In practice the requirement travels back to the factory as a design brief: a gimbal, a selfie stick or a portable speaker with a built-in battery, placed on the EU market after 18 February 2027, needs a housing that opens with a screwdriver and accepts a new battery.
The exceptions are narrow
Article 11 allows a few exceptions. Two kinds of product may be designed so that only an independent professional, not the user, replaces the battery: appliances designed to work mainly where they are regularly splashed, rinsed or immersed and meant to be washable, where this is needed for the safety of the user and the appliance; and professional medical imaging and radiotherapy devices and in-vitro diagnostic devices. The rule doesn't apply at all where a continuous power supply is necessary and the battery has to stay permanently connected, either for the safety of the user and the appliance or, in products whose main job is to collect and supply data, for data integrity. Stricter EU rules for electrical equipment take precedence: for smartphones and tablets, the Commission's guidance points to the ecodesign regulation (EU) 2023/1670. The list can change, so check the current text before relying on an exception.
What to ask a supplier now
The tooling for products sold in 2027 is being made now. Three questions settle most of it:
- Does the product have a portable battery, and can the user remove it with commercially available tools, without heat, solvents or a proprietary tool?
- If not, which exception applies, and what documents support it?
- Will spare batteries and instructions be available for five years after the last unit ships?
What Clacta shows
Clacta does not test products or judge their design. A report shows the records that exist about the company. Where the company holds IECEE CB certificates, a signed-in reader sees them grouped by the IEC standard they were tested against, for example IEC 62133 for portable rechargeable cells, with how many are current and how many cancelled, as the IECEE register publishes them. A CB certificate shows that a cell or product was safety-tested to that standard. It says nothing about whether the battery can be removed. That question is the one above, and it is the factory's to answer.
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries, Articles 11 and 96, published in the Official Journal of the European Union (OJ L 191, 28.7.2023) by the European Parliament and the Council; Article 11 applies from 18 February 2027
- Commission Notice – Commission guidelines to facilitate the harmonised application of provisions on the removability and replaceability of portable batteries and LMT batteries in Regulation (EU) 2023/1542 (C/2025/214), OJ C, 10.1.2025
- Regulation (EU) 2019/1020 on market surveillance and compliance of products, Article 3(21) (definition of end-user)
- IECEE CB Scheme certificate register, operated by IECEE, for CB certificates as published
Cross-check, Clacta.