EU Battery Regulation 2027: replaceable batteries and the instructions you must publish online

1The short version

• Article 11 of Regulation (EU) 2023/1542, the EU Battery Regulation, applies from February 18, 2027 (Article 96(2)(a)).
• If you place products with portable batteries on the EU market, the battery must be readily removable and replaceable by the end user at any time during the product's lifetime. The duty covers the entire battery, not individual cells (Article 11(1)).
• The products must come with instructions and safety information on the use, removal and replacement of the batteries, made available “permanently online, on a publicly available website, in an easily understandable way for end-users” (Article 11(1)).
• A portable battery is sealed, weighs 5 kg or less, isn't designed specifically for industrial use and isn't an electric vehicle, LMT or SLI (starter) battery (Article 3(1)(9)). LMT batteries, which power light means of transport such as e-bikes and e-scooters, must be replaceable by an independent professional (Article 11(5)).
• Spare batteries must stay available for at least five years after the last unit of a model is placed on the market (Article 11(7)), and software must not be used to block replacement with a compatible battery (Article 11(8)).
• Exceptions exist (Article 11(2) and (3)). Delegated act C(2026) 5031 of July 14, 2026 would add more. On October 16, 2026 it was not yet in the Official Journal, so it is not in force.
• Also from February 18, 2027: a QR code on all batteries (Article 13(6)) and a battery passport for LMT, industrial (over 2 kWh) and electric vehicle batteries (Article 77).

2What “readily removable and replaceable” means

Removable: a portable battery is readily removable by the end user “where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product” (Article 11(1)). Recital 38 describes commercially available tools as tools on the market to all end users, usable without proof of proprietary rights.

Replaceable: a battery counts as readily replaceable where, after removal, it can “be substituted by another compatible battery without affecting the functioning, the performance or the safety” of the appliance or light means of transport (Article 11(6)).

The Commission's guidelines (notice C/2025/214 of January 10, 2025) are not legally binding, but they show how the Commission reads Article 11. The end user is an adult without specific experience or qualifications in replacing batteries. A compatible battery doesn't put the user's or the device's safety at risk and lets the device work as intended.

Whether a product passes these tests is a design question for your engineers and compliance team. We don't assess product design or classify products.

3What the public instruction page should hold

Article 11(1) sets the minimum, two items come from the Commission's guidelines, and the rest is our view of good practice. Publish the page at an address your company controls, so it survives website redesigns. One page per model can hold:

1. Model identification Good practice. Model name, battery type and a photo, so users find the right page.
2. When to replace Good practice. The signs of a worn battery that your manual describes.
3. Tools Good practice to list them. Removal by the end user must work with commercially available tools, and specialized tools only count if they come free with the product (Article 11(1)).
4. Steps with images Required: instructions on the use, removal and replacement of the battery (Article 11(1)). A picture for each numbered step is good practice.
5. Safety warnings Required (Article 11(1)). Copy them unchanged from your manual.
6. Compatible battery specifications Recommended. The guidelines call it “strongly recommended” to include replacement instructions and “the technical specifications that compatible batteries need to meet in order to be safe”.
7. The old battery Recommended. The guidelines ask for clear advice so that waste batteries aren't thrown away with other waste, and on taking them to a separate collection point.
8. Where to buy a spare Good practice. Article 11(7) requires spares for at least five years after the last unit, at a reasonable and non-discriminatory price, so link to where users can order one.
9. Languages Required: a form end users easily understand. Article 11 names no languages; see which languages your instructions need.
10. Captions and transcript Good practice. The video then works without sound, and the transcript can be printed.

4Exemptions and edge cases

The current text of Article 11(2) lets two groups of products keep the battery replaceable only by independent professionals: washable or rinseable appliances specifically designed to operate primarily in an environment regularly subject to splashing water, water streams or water immersion, where safety requires it; and professional medical imaging and radiotherapy devices and in vitro diagnostic medical devices. Under Article 11(3), the paragraph 1 obligations don't apply where continuous power and a permanent connection to the battery are required for safety, or for data integrity in products whose main function is to collect and supply data.

Batteries that power e-bikes and e-scooters are the Regulation's own examples of LMT batteries (recital 12). An LMT battery is sealed, weighs 25 kg or less and provides power for traction (Article 3(1)(11)). It falls under Article 11(5), which requires replacement by an independent professional, and under Article 11(7) on five years of spares. The guidelines recommend replacement instructions for LMT batteries too; see e-bike assembly videos.

Stricter rules on battery replacement in EU law for specific electrical and electronic equipment still apply (Article 11(1), last subparagraph).

Delegated act C(2026) 5031, adopted by the Commission on July 14, 2026, would replace Article 11(2). It enters into force 20 days after publication in the Official Journal and had not been published on October 16, 2026, so check EUR-Lex before relying on it. Points (a) and (c) to (h) apply only “where such derogation is required to ensure the safety of the user and the appliance.” Its list, quoted:

• (a) “appliances, including wearable devices, specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion, and that are intended to be washable or rinseable”;
• (b) professional medical imaging and radiotherapy devices and in vitro diagnostic medical devices, as today;
• (c) “wearable devices for which the safety, durability, or water resistance may be compromised by user access to the battery” and which are “too small to allow the end-user to properly and safely handle a battery replacement” or “rely on a compact, sealed enclosure to maintain functional integrity, including protection against dust, and shock”;
• (d) until July 31, 2030, “electric toys that incorporate rechargeable batteries”, where the nature or size of the toy makes the derogation necessary for its safety;
• (e) “wireless thermometer probes specifically designed for food contact during food preparation processes”;
• (f) products within the scope of Article 1 of Directive 2014/34/EU (equipment for potentially explosive atmospheres, ATEX);
• (g) “on-body delivery systems specifically designed for the subcutaneous administration of medicinal products”;
• (h) “telematics devices intended for roof mounted installation in agricultural and construction machinery and designed to be exposed to harsh vibrations, dust and wet conditions during their intended use”.

5Where a video fits

A 60 to 90 second video per model shows the removal and replacement as it happens: which screw, which latch, which way the new battery goes in. Put it on the same public page as the written steps and warnings.

Article 11(1) asks for instructions and safety information, and nothing in it says a video can replace them. Treat the video as a complement and keep the steps as text, which can be printed, translated and read by screen readers.

A QR code on the product, box or manual can open the page. That code is separate from the battery QR code of Article 13(6), which leads to battery information such as the EU declaration of conformity, or to the battery passport. Our QR video manuals open in the phone's language, and the QR code on packaging guide covers size and placement.

We make each video from your official manual, keep its safety notes unchanged, and start animating only after your team approves the script. You get the files with captions for your own page. A Quick Start video (60 to 90 seconds, $490 with three languages) covers one model. For several countries, see video instructions for manufacturers.

6Timeline and checklist to February 18, 2027

July 14, 2026: C(2026) 5031 adopted, not yet in force on October 16, 2026. February 18, 2027: Article 11, the battery QR code and the battery passport apply. July 31, 2030: end of the toy derogation in C(2026) 5031.

1. List your models Every product with a portable or LMT battery that you will place on the EU market from February 18, 2027.
2. Check the design With your engineers: removal by the end user with commercially available tools, compatible replacements, no software lock.
3. Check the exceptions Article 11(2) or (3), and whether C(2026) 5031 is in the Official Journal. For the wet-environment derogation, the guidelines expect evidence in the product documentation.
4. Plan spares At least five years after the last unit of each model is placed on the market, at a reasonable and non-discriminatory price.
5. Write the page Steps and safety information from your manual, compatible battery specifications and advice on the old battery.
6. Publish it for good One public page per model, at an address you control, online permanently.
7. Add the video and the code A short replacement video next to the written steps, and a QR code that opens the page.

7What we checked

We read Regulation (EU) 2023/1542 as published (OJ L 191, July 28, 2023) and its consolidated text of August 13, 2026, in which Article 11 is unchanged, plus Commission notice C/2025/214 and the adopted text of C(2026) 5031.

General information, not legal advice. Checked against the official texts on October 16, 2026.

Questions