Appliances specifically designed to operate in a wet environment

Appliances 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, may be designed in such a way as to make the battery removable and replaceable only by independent professionals. Recital (39) of Regulation (EU) 2023/1542 specifies that ‘this derogation should only apply when it is not possible, by way of redesign of the appliance, to ensure the safety of the end-user and the safe continued use of the appliance after the end-user has correctly followed the instructions to remove and replace the battery’. Therefore, the following indicators are therefore all relevant for interpreting and applying the criteria for the applicability of a derogation for an appliance operating in a wet environment: ‘specifically’: the appliance is designed with the main purpose to operate in the environment described; ‘primarily’: the environment described is the primary environment of the appliance, as Recital 39 explicitly specifies, ‘for the majority of the active service of the appliance’. In other words, not just an environment in which the device may only coincidentally or accidentally operate; ‘washable or rinseable’: the appliance is intended to be washable or rinseable; ‘compromising safety’: there is evidence in the product documentation when placing the product on the market that battery replaceability and removability by end-users would compromise the safety of the user or the appliance; ‘no way to redesign’: there is evidence in the product documentation when placing the product on the market that there is no way to redesign the appliance with the current state of the art technology, without severely affecting the health and safety of the end-user or the performance and functionality of the product. The Ingress Protection (IP) rating system defined in standard IEC 60529 (specifically, the second numeral related to water, as depicted in Figure 1) offers an indicative guide to identify the environment referred to in the above-mentioned criteria. Nevertheless, an IP rating grades resistance of an enclosure against the intrusion of dust or liquids; it is not limited only to appliances that operate in a certain primary environment for a given part of their active service, nor does it establish whether redesign is possible or not. As such, the IP rating alone is considered as sufficient to demonstrate the compliance with the above-mentioned criteria. Specifically, the case of ‘splashing water’ referenced in Article 11 of Regulation 2023/1542 is equivalent to an IPX4 rating (class number 4 described in Figure 1 below), the case of ‘water streams’ is equivalent to IPX5 and IPX6 (classes number 5 and number 6), and the case of ‘water immersion’ is equivalent to an IPX7 rating (class number 7). On points (ii) and (iii), a representative example of products primarily operating in such environment can be oral hygiene appliances (e.g., toothbrushes as in IEC 60335-2-52), and shavers, hair clippers and epilators (as in IEC 60335-2-8). At the same time, point (iv) indicates that there may still be appliances used in wet environment that incorporate batteries that are removable and replaceable by end-users, as long as this does not compromise safety. Examples of such appliances include toothbrushes and shavers powered by portable batteries of general use. Figure 1 Ingress Protection (IP) ratings guide for water (source IEC 60529)

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.