§2.2 Interaction with other applicable EU legislation

Article 11(1) stipulates that the provisions in its paragraph shall be without prejudice to any specific provisions ensuring a higher level of protection of the environment and human health relating to the removability and replaceability of portable batteries by end users laid down in any Union law on electrical and electronic equipment as defined in Article 3(1), point (a), of Directive 2012/19/EU on Waste Electrical and Electronic Equipment (3). At the time of adopting these guidelines, the only EU law that sets out specific provisions is Regulation (EU) 2023/1670 (4) laying down ecodesign requirements for smartphones, mobile phones other than smartphones, cordless phones and slate tablets. On the replaceability of portable batteries, this regulation requires that individuals without any specific repair experience or related qualifications (referred to as laymen) (5) or those with general knowledge of basic repair techniques and safety precautions (referred to as generalists) must be able to replace the battery. However, in the latter case, the battery and the device also have to meet stricter durability requirements (6). Consequently, in the case of portable batteries included in products covered by Regulation (EU) 2023/1670, the removability and replaceability obligations set out in Annex II of that Regulation prevail over those set out in Regulation (EU) 2023/1542.

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