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The European Commission has identified several exceptions to the current EU regulation on batteries. These exceptions will exempt six categories of electronic devices from the requirement to be equipped with user-replaceable batteries. This list includes wearable devices, such as smartwatches.
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The EU began implementing the new Battery Regulation in 2023 as part of the European Green Deal, but the requirement for user-replaceable batteries will not take effect until 2027. This regulation has already prompted Nintendo to announce a new version of the Switch 2 with a user-replaceable battery.
According to the draft list of exemptions prepared by the European Commission, the requirement for user-replaceable batteries does not apply to wearable devices, certain medical devices, electronic toys, portable thermometers, telematics devices for installation on vehicle roofs, as well as devices intended for use in “explosive atmospheres.”
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Regarding which specific devices fall under the category of wearables, the European Commission explicitly mentions smartwatches, fitness trackers, smart glasses, and other electronic devices integrated into clothing or accessories. Although the new devices are not required to be equipped with batteries that users can replace themselves, many of them must still be repairable by qualified technicians. Furthermore, although wireless earbuds are not specifically mentioned in the draft list of exceptions, devices such as Apple AirPods may also fall under this exemption as “wearable devices whose safety, durability, or water resistance could be compromised if the user gains access to the battery.”
Smartphones are not included in the list of exceptions; however, current regulations allow for battery replacement not only by simply removing the back cover and installing a new battery. According to current EU regulations, replacement is permitted provided that it does not require specialized tools or if such tools are provided by the smartphone manufacturer, and the procedure itself does not compromise the device’s safety. For example, Apple’s Self Service Repair program likely meets these requirements.
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Once approved by the European Commission, the draft exemptions will be forwarded to the European Parliament and the Council of the European Union for further consideration. If there are no objections, the new exemptions will take effect 20 days after their publication in the Official Journal of the European Union.
When the European Union adopted the new Battery Regulation, it emphasized that it is part of a strategy to create a more environmentally friendly circular economy. At that time, the European Commission noted that the requirement for manufacturers to produce devices with replaceable batteries “will extend the service life of these products until their final disposal, promote their reuse, and help reduce post-consumer waste.”
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