From 18 February 2027, battery removability replaceability stops being a design preference and becomes a legal condition for selling products in the EU. Article 11 of the EU Battery Regulation (Regulation (EU) 2023/1542) requires that portable batteries built into products placed on the EU market are readily removable and replaceable by the end user throughout the product’s life. For design engineers and battery compliance leads, this is a hardware decision with a fixed deadline, not a documentation task.
Two documents published on 14 July 2026 changed what teams need to plan for: a Commission delegated act that reshaped the exemption list, and updated Commission guidelines on how the rule is applied. Both are recent and still working through the EU process, which means many internal design reviews have not yet caught up.
This guide explains what Article 11 requires, who must be able to replace the battery, which products qualify for a derogation, and the obligations that teams most often miss. For a wider view of the framework, see Certivo’s EU Batteries Regulation overview.
If you want to understand your exposure before the deadline, you can book a compliance review to map Article 11 against your current product designs.
Key Takeaways
📌 Article 11 applies from 18 February 2027 and governs the design of portable and LMT batteries incorporated into products sold in the EU.
⚠️ A derogation changes who replaces the battery, not whether it must be replaceable. Only Article 11(3) removes the design duty entirely.
📄 A battery is “readily removable” when it comes out with commercially available tools, without proprietary tools, heat or solvents, referencing standard EN 45554:2020.
📊 The 14 July 2026 delegated act (C(2026) 5031) adds six new categories to the Article 11(2) partial-derogation list, growing it from two to eight.
⏳ Portable and LMT batteries must remain available as spare parts for at least five years after the last unit of a model is placed on the market (Article 11(7)).
🏭 Earbuds, smartwatches, fitness trackers, electric toothbrushes, cordless tools and many battery toys are directly in scope.
🔗 The same date brings a QR code on all batteries and a battery passport for LMT, industrial above 2 kWh and EV batteries, which are separate obligations from Article 11.
What Article 11 of the EU Battery Regulation requires
Article 11(1) sets a single, demanding duty. Anyone placing a product with an incorporated portable battery on the EU market must ensure the battery is readily removable and replaceable by the end user at any point during the product’s lifetime. The obligation applies to the complete battery, not to individual cells inside it.
The rule also covers the surrounding conditions. Manufacturers must supply clear removal and replacement instructions and safety information with the product and keep them permanently available online. A compatible replacement battery must work without impairing the product’s function, performance or safety. Under Article 11(8), software must not be used to block replacement with a compatible battery.
You can verify the legal text through the official EUR-Lex record for Regulation (EU) 2023/1542.
What “readily removable” means in practice
A portable battery is considered readily removable where it can be taken out using commercially available tools, without specialised tools (unless supplied free of charge with the product), proprietary tools, thermal energy or solvents. The Commission guidelines align these tool categories with the standard EN 45554:2020 on assessing repairability.
Two practical points follow for design teams. Standard screws are acceptable because a standard driver is commercially available. Where disassembly needs fasteners that cannot be reused, those fasteners must also be available as spare parts.
Battery removability replaceability test for end-user removal under Article 11
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Replaceability, not just removability
Removability is only half of the duty. Replaceability means a user can fit a compatible battery and return the product to normal function. A design that lets the battery come out but cannot accept a standard replacement, or that pairs the battery to the device through software locks, does not meet Article 11. Teams building this logic into firmware should review it against the Article 11(8) software constraint early, because it is a redesign risk rather than a labelling fix.
Portable versus LMT batteries: who must be able to replace them
Article 11 treats two battery types differently. Portable batteries must be replaceable by the end user. Light means of transport (LMT) batteries, used in products such as e-bikes and e-scooters, must be removable and replaceable by an independent professional, not necessarily the owner.
Battery / product type | Who must be able to replace it | Legal basis |
|---|---|---|
Portable batteries in everyday devices | End user, with commercially available tools | Article 11(1) |
Portable batteries in a derogated category | Independent professional, non-destructively | Article 11(2) + delegated act |
LMT batteries (e-bikes, e-scooters) | Independent professional | Article 11(1), LMT provisions |
Industrial above 2 kWh and EV batteries | Not covered by Article 11 | Article 77 (battery passport) |
This distinction matters for product classification. The category is not decided by a simple energy cut-off. Product purpose, weight and the battery definition each need separate assessment, which is where cross-functional errors between engineering and regulatory teams tend to appear. Certivo’s materials and environmental compliance workflows are built to hold that product-level logic in one place.
The two 14 July 2026 documents every design team needs
On 14 July 2026 the European Commission published two separate instruments. Reading them as one document is a common and costly mistake, because they do different jobs.
Commission Delegated Regulation C(2026) 5031: six new derogation categories
Adopted under the empowerment in Article 11(4), this delegated act replaces the Article 11(2) partial-derogation list in full. The original list held two categories: appliances designed to operate in or be exposed to water, and professional medical imaging, radiotherapy and in vitro diagnostic (IVD) devices. The delegated act adds six new categories, bringing the list to eight.
The six additions cover wearable devices that are too small or too tightly sealed for safe end-user replacement, electric toys with rechargeable batteries (a temporary derogation until 31 July 2030), food probes, equipment for potentially explosive atmospheres (ATEX), on-body drug delivery systems, and certain agricultural telematics devices.
One point needs emphasis for compliance engineers. A partial derogation does not remove the design duty. The battery must still be removable and replaceable by an independent professional, non-destructively, using commercially available tools. Only the full derogation in Article 11(3) releases a product from the design requirement. Based on currently available regulatory guidance, C(2026) 5031 was adopted but had not yet completed the Parliament and Council scrutiny period or been published in the Official Journal at the time of writing, so teams should confirm its final entry into force before relying on a new category. The Commission’s record is published by DG Environment.
Commission Notice C(2026) 5032: updated guidelines
The second document, Commission Notice C(2026) 5032 final, updates the guidelines that explain how Article 11 is applied in practice. Guidelines are interpretive rather than binding, but market surveillance authorities use them, so they shape how the rule is enforced. They confirm, for example, that the wet-environment route can cover qualifying wearables such as earbuds and watches, which may reduce redesign pressure for some product lines.
Battery removability replaceability derogation list expanding from two to eight categories
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The five-year spare-parts duty teams most often miss
Article 11(7) is the obligation that rarely reaches the design review. Relevant portable and LMT batteries must remain available as spare parts for at least five years after the last unit of that equipment model is placed on the market. This is a commercial and supply-chain commitment, not only an engineering one.
It affects sourcing contracts, service operations and end-of-life planning. A product that is compliant at launch can fall out of compliance later if the spare battery, or a non-reusable fastener needed to fit it, is no longer available. Mapping this duty to each model and its service window is exactly the kind of long-horizon tracking that spreadsheets lose. Certivo’s BOM-level compliance tracking is designed to hold that model-to-obligation link over time.
What is in scope, and what sits outside Article 11
Not every battery-powered product is governed by Article 11, and the boundaries carry real consequences.
Smartphones and tablets are covered by the Ecodesign Regulation (EU) 2023/1670, whose Annex II requirements prevail for those products. Teams should not apply Article 11 to a smartphone in place of the Ecodesign rules.
A product whose primary function is to power other products is itself a portable battery and sits outside Article 11.
Individual units placed on the market before 18 February 2027 do not need to meet the requirement. This is unit-level timing, not a product-line grandfathering clause, so a model you keep selling after the date must comply.
The same 18 February 2027 date also triggers a QR code on all batteries and a battery passport for LMT, industrial above 2 kWh and EV batteries under Article 77. Portable batteries are not in the passport scope, a distinction worth protecting in internal planning. For the wider traceability picture, see Certivo’s Digital Product Passport framework page and the related DPP backbone analysis.
Who is affected
The rule reaches well beyond battery makers. It lands on the brand that places the finished product on the EU market.
🏭 Consumer electronics and consumer goods. Earbuds, smartwatches, fitness trackers, electric toothbrushes and cordless gadgets are squarely in scope. These teams carry the heaviest redesign exposure, and Certivo serves them through its consumer goods and electronics manufacturing workflows.
🏭 Medical and industrial devices. Several derogations touch this group, but classification is delicate and each product must be assessed against the specific category wording. Certivo supports medical device manufacturers managing that judgment.
🏭 Mobility and LMT. E-bike and e-scooter producers must meet the professional-replacement route and track module-level design expectations, a growing area for automotive and mobility suppliers.
The compliance and commercial risk of getting Article 11 wrong
For leadership, Article 11 is a market-access question. A non-compliant design is not a paperwork gap that can be closed after launch. It can require tooling changes, enclosure redesign and revised service logistics, each with long lead times. A redesign started in early 2027 will almost always miss the deadline, because the date is when the requirement applies, not when teams should begin reviewing.
The exposure is concrete: products held at the border or pulled by market surveillance authorities, lost shelf space with retailers that demand compliance evidence, and the cost of an unplanned redesign cycle. The practical defence is to treat removability as a design input now and to keep the supporting evidence, instructions, spare-parts plans and derogation justifications, audit-ready rather than assembled under pressure.
A design-for-compliance readiness checklist
Use this as a working review for each in-scope model:
Classify the battery and product as portable, LMT, or out of scope, and record the reasoning.
Confirm the removal route meets the commercially available tools test, with no heat, solvents or proprietary tools for end-user removal.
Check replaceability, including compatible-battery fit and the absence of software locks under Article 11(8).
Assess any derogation against the exact category wording, and remember a partial derogation still requires professional replaceability.
Plan the five-year spare-parts duty, including non-reusable fasteners, across sourcing and service.
Prepare instructions and safety information for supply with the product and permanent online availability.
Hold the evidence so it can be produced for customer audits and market surveillance without a scramble.
This connects naturally to launch planning. Certivo’s launch new products faster workflow brings compliance checks into the design stage rather than after it.
How Certivo supports battery design-for-compliance
Article 11 is a data and evidence problem as much as a hardware one. Teams need to know which models are in scope, which route applies, what evidence exists, and when a spare-parts obligation expires. Certivo acts as the system of record for that information, linking obligations to specific products and bills of materials.
CORA, Certivo’s regulatory intelligence layer, tracks changes such as the 14 July 2026 delegated act and updated guidelines and maps them to the products they affect, so a design team learns about a derogation that helps or a requirement that bites while there is still time to act. Combined with automated supplier documentation and continuous, audit-ready records, this shifts battery compliance from a reactive deadline exercise toward continuous readiness. Certivo does not remove the design duty, and no platform makes a product audit-proof. The goal is fewer surprises, faster evidence retrieval and clearer visibility across the portfolio.
Before the February 2027 deadline narrows your options, speak with a compliance specialist to review Article 11 against your product designs and build an evidence plan your customers and EU authorities can rely on.
Kunal Chopra
Kunal Chopra is the CEO of Certivo, an AI-driven compliance management platform revolutionizing how manufacturers navigate regulatory challenges. With a career spanning over two decades, Kunal is a seasoned technology leader, 3x tech CEO, product innovator, and board member with a passion for driving transformative growth and innovation.
Before leading Certivo, Kunal spearheaded successful transformations at renowned companies like Beckett Collectibles, Kaspien, Amazon, and Microsoft. His strategic vision and operational excellence have led to achievements such as a 25x EBITDA valuation increase at Beckett Collectibles and a 450% shareholder return at Kaspien. He has a track record of turning challenges into opportunities, delivering operational efficiencies, and driving market expansions.
Kunal’s deep expertise lies in blending technology and business strategy to create scalable solutions. At Certivo, he applies this expertise to empower manufacturers, using AI to turn product compliance from an operational burden into a strategic advantage.