New Updates to EU Battery Regulation — Scope of Exemptions for Removable Portable Batteries to Be Expanded

On April 28,2026,the European Commission’s Directorate-General for Environment(DG ENV)released a revised draft on exemptions regarding the detachability and replaceability of portable batteries,supplementing exemptions to Article 11 of EU Battery Regulation (EU) 2023/1542,which stipulates end-users shall be able to remove portable batteries by themselves.

Six additional categories of products including wearable devices, electric toys and ATEX explosion-proof equipment are added to the exemption list.Exempted products are no longer required to support battery removal and replacement by end-users.Instead,battery replacement can only be conducted by qualified professional technicians.This revision greatly accommodates the trends of product miniaturization and integrated design.

In the future,compact sealed,waterproof,explosion-proof,medical and food-contact products will be freed from the mandatory rule of user-replaceable batteries.Professional-only battery replacement is permitted,which better meets the demands of integrated and micro-sized product design.

Regulatory Background

Under the current EU Battery Regulation,starting from February 2027, portable battery-powered products sold in the EU market shall in principle allow end-users to detach and replace batteries without special tools.

Nevertheless,self battery replacement may trigger potential safety hazards or damage product integrity for certain products due to requirements such as waterproof & dustproof performance,ultra-compact size,explosion-proof standards,medical safety and food contact safety. Hence the EU launched the exemption mechanism,allowing exempted products to adopt professional-only battery replacement solutions.

Products Eligible for Professional-only Battery Replacement per the Revised Draft

(a) Washable water-resistant devices(including wearables)Devices exposed to splashing,running or immersed water and designed to be rinsed or cleaned,such as waterproof wearables,electric toothbrushes and water flossers.

(b) Professional medical devices (existing exemption) Medical imaging equipment,radiotherapy devices and in vitro diagnostic (IVD) devices.

(c) Compact sealed wearable devices (newly added) Wearables with overly small sizes that make safe user battery replacement impossible,or products relying on sealed housings for dustproof,shockproof and waterproof functions.

(d) Electric toys(newly added,valid until July 31, 2030)Rechargeable battery-operated toys with sizes and structures unsuitable for user self-replacement for safety purposes.

(e) Food-contact wireless temperature probes(newly added)Wireless temperature measuring devices specially designed for direct food contact and food processing scenarios.

(f) ATEX explosion-proof equipment(newly added)Devices for explosive hazardous environments complying with Directive 2014/34/EU,including explosion-proof sensors,motors and remote terminals.

(g) Subcutaneous drug delivery systems(newly added)Dedicated devices for subcutaneous drug administration.

(h) Telematics equipment for agricultural,forestry and construction machinery (newly added) Remote monitoring devices installed on machinery, exposed to severe vibration,dust and humid environments for long-term operation.

All above exemptions apply only when necessary to ensure user safety and product operational safety,and are not automatically applicable.

Impacts on Export Enterprises

Favorable for miniaturized,waterproof and sealed product design Manufacturers of wearables,smart bands,waterproof home appliances and micro sensors are no longer forced to design user-detachable battery structures,gaining higher design flexibility.

Clear transition period for electric toys Rechargeable electric toys are allowed to adopt professional battery replacement solutions before July 31,2030,granting enterprises sufficient time for product adjustment.

Reduced compliance pressure for explosion-proof,medical and food-contact equipment The new rules align well with industry-specific safety standards,avoiding hidden risks caused by rigid user-replaceable battery design requirements.

Professional maintainability still mandatory Exemption does not mean non-removable batteries.Batteries must be safely detachable and replaceable by professional technicians.Enterprises need to prepare complete maintenance documents and supporting dedicated tools.

The draft is now open for public consultation until May 26,2026.Once officially enacted,it will directly affect CE-Battery compliant product design and technical documentation compilation.

Suggestions for EU-oriented exporters

1. Sort out product categories to confirm qualification for relevant exemptions;

2. Specify professional battery replacement procedures in user manuals and technical files;

3. Consult testing and certification institutions in advance to avoid compliance rework caused by unqualified structural design.

The EU Battery Regulation is being further refined,shifting from uniform user-replaceable battery rules to safety-oriented classified exemptions. It not only promotes waste battery recycling but also respects differentiated safety and design demands across various industries. Overseas suppliers are advised to closely follow the official release of the final regulation version,timely adjust product design and compliance strategies to ensure smooth market access in the European Union.

HUAK Testing Certification Service Advantages

HUAK Testing covers an area of over 4,000 square meters, including EMC, RF, 5G NR/6G (RF), Safety, Physical, Battery, and Chemical testing laboratories. It supports a wide range of products—from consumer goods like mobile phones, computers, toys, apparel, footwear, and cosmetics, to industrial control equipment and smart home devices—helping clients meet global market access requirements. The company is equipped with internationally advanced professional testing equipment and has assembled an elite team of senior industry experts and technical professionals. Team members, with their solid professional knowledge and rich practical experience, are able to accurately interpret various complex standards and technical requirements. As a well-known third-party testing laboratory in China, HUAK has been recognized by many international organizations, including the China National Accreditation Service（CNAS） for Conformity Assessment and the US A2LA. HUAK Testing is also the designated testing and certification service provider for Amazon, and maintains close cooperation with internationally renowned notified bodies such as MICOM, element, MET, and Germany's PHOENIXTESTLAB GmbH.