According to the EU Battery Regulation, portable batteries installed in electrical and electronic equipment must be easily removable and replaceable by end users. The main goal is to support the continued use of battery-powered devices, as well as proper disposal and recycling of batteries. However, the regulation allows for exceptions to ensure consumer safety is not compromised. In these cases, it is sufficient for batteries to be removable or replaceable by independent specialists. As part of a current EU initiative, a binding list is being drawn up to specify which products or product categories are exempt from battery removability requirements. This list is intended to close existing gaps and provide clarity for both producers and consumers.
VERE e.V. has issued a statement on this initiative. The wording for the exclusion criteria must be carefully drafted to avoid any room for interpretation. This is particularly relevant for devices that should explicitly fall outside the scope of the exemption, such as electric toothbrushes, e-cigarettes, smartphones, and devices integrated into textiles or toys. VERE therefore recommends introducing a non-exhaustive negative list to clearly specify which products are not covered. At the same time, VERE supports establishing a positive list of products for which permanently installed batteries are acceptable. A key example is smoke alarms, where continuous operation is essential to ensure life-saving functionality. In such cases, permanently installed batteries reduce the risk of failure, making this approach justified from both a safety and compliance perspective. A combined system of positive and negative lists would provide greater transparency and clearly define which products may include permanently installed batteries and which are explicitly excluded.
VERE e.V. is in contact with all relevant stakeholders and keeps its members informed about further developments via the “VERE Insider”.
Not a VERE member yet? Become a VERE member today!
