§2 GENERAL CONSIDERATIONS

The removability of portable and LMT batteries is understood to be possible when the battery can be safely taken out of a device by the end user or an independent professional, with or without the use of tools, avoiding damage to the battery and to the device. In turn, the replaceability of portable and LMT batteries means that the battery can be removed and replaced with another battery without damaging or destroying the battery or the device where it is incorporated. This, therefore, enables further operation without affecting the functioning, performance or safety of the device. The obligation in Article 11(1) of Regulation (EU) 2023/1542 on the removability and replaceability of portable batteries by the end user is applicable to entire batteries, and not to individual cells. The end user should be a person having attained the age of majority without any specific experience or related qualifications related to removing or replacing batteries. In the case of LMT batteries, the obligation in Article 11(5) concerning the removability and replaceability by independent professionals is, additionally, applicable at the level of the battery cells included in the battery. Section 3 of the present guidelines discusses the concept of independent professionals. When tools other than commercially available tools are required for independent professionals to have LMT batteries removed and replaced, these should be made available to them at a reasonable and non-discriminatory price. This should not deter access to such tools, thereby impeding the removability and replaceability of batteries. Once batteries are removed, it is important that the dangers associated with waste batteries are addressed. The information provided to the user should include clear advice on the next steps required to ensure that waste batteries are not discarded with other waste, in particular municipal waste. Information should also be provided on the correct handling, packaging, storage and transport of the waste battery to a separate collection point or treatment facility. Small lithium-based portable batteries in certain product categories such as greeting cards, smart textiles, wearables, and electronic cigarettes, may cause fire incidents in waste treatment facilities if they are discarded together with those products. It is important that portable batteries can be removed and replaced by the end-user, as required by the general provision in Article 11(1).

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07