Batteries Regulation Guidelines: Removability and Replaceability of Portable and LMT Batteries

These Commission guidelines, issued under Article 11(9) of the Batteries Regulation (EU) 2023/1542, are interpretative and not legally binding (binding interpretation belongs to the Court of Justice of the EU). They explain how the Article 11 removability and replaceability requirements for portable batteries and light means of transport (LMT) batteries apply: what "readily removable and replaceable by the end-user" means, which tools may be required, who counts as an independent professional, how to assess derogations for wet-environment appliances and medical devices, compatible batteries, spare-part availability, and software that must not block replacement. Article 11 applies from 18 February 2027, so product design needs to adapt in advance.