Navigating 2027 requirements for removability and replaceability of batteries in electrical products
27 Jun 2025
Increased focus on repairability for products using portable and LMT batteries
By now, most manufacturers of battery-powered products will be aware of the increasing emphasis on sustainability and repairability in the European Union's regulatory frameworks in general.
More specifically, in the battery space, the EU Battery Regulation (EU) 2023/1542, will introduce stringent requirements for the removability and replaceability of batteries in some battery powered products in 2027. Effective from February 18, 2027, these requirements aim to enhance product longevity and facilitate battery recycling.
Which products are affected?
The EU battery regulation defines different battery categories based on their application, and the requirements on removability and replaceability will only apply to two of these categories:
- Products incorporating portable batteries
- Products incorporating light means of transport (LMT) batteries
Portable batteries are smaller batteries (< 5 kg) not designed for industrial use, and light means of transport (LMT) batteries are batteries designed to provide electric power for the traction of wheeled LMT vehicles such as e-bikes, e-scooters and motorcycles.
Understanding the general rule
The regulation mandates that:
- Portable batteries in products shall be readily removable and replaceable by the end-user. The end-user shall be able to remove the battery using commercially available tools without the need for specialized tools unless the specialized tools are provided free of charge.
- Products with portable batteries shall be accompanied with instructions and safety information on the use, removal and replacement of the batteries.
- Light means of transport (LMT) batteries, as well as individual battery cells incorporated in the batteries, shall be readily removable and replaceable by an independent professional at any time during the lifetime of the product.
- A battery is considered readily replaceable where after its removal from a product, it can be substituted by another compatible battery without negatively affecting the functioning, the performance or the safety of the product.
- Manufacturers must ensure that batteries are available to independent professionals and end-users as spare parts for at least five years after the last unit of the product model is placed on the market.
- Software should not prevent the replacement of batteries with compatible alternatives.
Derogations and exemptions
The regulation acknowledges that certain products may not be suitable for these requirements due to specific operational needs. For instance, products designed for wet environments or those requiring continuous data collection may be exempt or partially exempt. The Commission can also adopt delegated acts to exempt additional products based on science-based safety concerns.
Official guideline
To aid manufacturers in complying with these requirements, the Commission has published an official guideline (Commission notice C/2025/214). This document provides context and technical elements, including definitions of key terms like "commercially available tools" and "compatible battery". The document also highlights additional derogations for products such as implantable medical devices and other applications where removability is associated with safety concerns for the end-user.
Preparing for compliance
It is crucial for manufacturers to start preparing for these changes now. Products that currently do not meet these requirements may need to be redesigned. The preparation process involves ensuring that batteries can be readily removed and replaced, the product is accompanied with the correct information and that spare parts are available for the required duration.
Partnering with experts
Navigating these regulatory changes can be challenging, but you don't have to do it alone. Intertek offers comprehensive support to help manufacturers comply with the new requirements. Our accredited testing laboratories and experienced electrical product and battery experts are ready to assist you in ensuring compliance while maintaining the quality and safety of your products.
As a manufacturer, embracing these changes will not only ensure compliance but also align your products with the growing demand for sustainability. If you haven’t yet, now is the time to start preparing to meet the February 2027 deadline.
Discover Intertek’s safety and compliance solutions for batteries and energy storage systems:
