Which products are exempt from the EU user-removable battery rule?
Eight kinds of product may make the battery replaceable only by independent professionals instead of by the user: three were in the 2023 Batteries Regulation, and Delegated Regulation 2026/1770 replaced the list on 11 November 2026 to add wearables, rechargeable toys, food probes, ATEX equipment, on-body drug pumps and machine telematics. Everything else sold in the EU from 18 February 2027 needs a battery the user can remove and replace with commercially available tools.
| Point | Exempt products (Art. 11(2)) | Examples | Condition |
|---|---|---|---|
| (a) | Appliances, now including wearables, designed to work mainly where they are regularly splashed, under running water or immersed, and meant to be washed or rinsed | Electric toothbrush, water flosser, shaver, swim-proof wearable | Only where needed for the safety of the user and the appliance |
| (b) | Professional medical imaging and radiotherapy devices, and in vitro diagnostic medical devices | Imaging equipment, IVD analysers | None stated |
| (c) | Wearables where user access to the battery could compromise safety, durability or water resistance, and that are too small for a safe battery change by the user, or rely on a compact sealed enclosure for protection against dust and shock | Smart ring, small fitness tracker, earbuds-size wearable, smart glasses | Only where needed for safety |
| (d) | Electric toys with rechargeable batteries, until 31 July 2030, where the nature or size of the toy makes it necessary for the toy's safety | Small rechargeable toys | Only where needed for safety; from 1 August 2030 the Toy Safety Regulation (EU) 2025/2509 rules |
| (e) | Wireless thermometer probes designed for food contact while cooking | Wireless meat probe | Only where needed for safety |
| (f) | Products in the scope of the ATEX Directive 2014/34/EU (explosive atmospheres) | Explosion-proof sensors, pumps, motors | Only where needed for safety |
| (g) | On-body delivery systems for injecting medicine under the skin | Wearable insulin or drug patch pump | Only where needed for safety |
| (h) | Telematics devices for roof mounting on farm and construction machines, exposed to harsh vibration, dust and wet conditions | Tractor or excavator roof telematics box | Only where needed for safety |
Exempt does not mean glued shut
- An exempt battery still has to be removable and replaceable by an independent repairer, not only by you.
- The battery still has to be sold as a spare part for at least five years after the last unit of the model is placed on the market, at a reasonable price (Art. 11(7)), and software must not block a compatible replacement (Art. 11(8)).
- Separately, the user-removable rule does not apply at all where the battery must stay permanently connected for the user's safety, or for data integrity in a product whose main function is collecting and supplying data (Art. 11(3)).
What "user-removable" means
The user must be able to take the battery out with commercially available tools. Specialised or proprietary tools are allowed only if supplied free with the product; heat and solvents are never allowed. The rule covers the whole battery, not the cells inside it, and removal and replacement instructions with safety information must come with the product and stay on a public website (Art. 11(1)). Replaceable means a compatible battery can go in without hurting the product's function, performance or safety (Art. 11(6)).
Dates
- 11 November 2026: Delegated Regulation 2026/1770 in force (the new list above).
- 14 December 2026 (expected): European Parliament vote on the battery simplification package, where the Council proposed an 18-month delay of Article 11 for the newly exempted categories only. Not final.
- 18 February 2027: Article 11 applies to products placed on the EU market from that day.
Sources: Regulation (EU) 2023/1542, Article 11; Delegated Regulation (EU) 2026/1770; European Commission, 14 July 2026; Council, 24 June 2026. The table paraphrases the legal text; the linked text governs.
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Or email chris@anvol.dev. This is an engineering assessment, not a legal opinion or a certification.