Battery removability and replaceability guidelines (2026 update)

Updated guidelines adopted by the Commission on 2026-07-14 under Article 11(9) of the Batteries Regulation (EU) 2023/1542 (C(2026) 5032) and published in the OJ on 2026-10-22 (C/2026/5531), updating Commission Notice C/2025/214 of January 2025; they were revised in spring 2026 following the first call for derogation applications and discussions with Member States and stakeholders. They explain removability, replaceability, commercially available, specialised and proprietary tools and independent professionals; the partial derogations of Article 11(2) (wet-environment appliances, medical and IVD devices, wearables); the full derogations of Article 11(3) on safety or data integrity grounds; and compatible batteries, spare part availability and software limitations. Article 11 applies from 2027-02-18. The guidelines are not legally binding; final interpretation rests with the Court of Justice.