EU2023/1542 - Page 1
Forum section: electronics / general

author: UglyKidJoe
author_rank: Newbie
timestamp: September 23, 2025, 05:46:51 am
content: Hi,I am not totally sure I am right here but I have a regulatory question about batteries. The European Union released a new battery regulation called 2023/1542 which forces basically anybody to produce products that allow the end user to replace the internal battery. is here anybody that heared about that? wording of this regulation is ... battery has to be readily removable and replaceable by the end-user at any time during the lifetime of the product.I would like to exchange ideas, feedbac and or just discuss the effects....

author: kite31
author_rank: Regular Contributor
timestamp: September 23, 2025, 06:30:37 am
content: I thought immediately of the difficulty in replacing batteries in Apple products, especially phones. It will not be a slip-in/slip-out operation as it was on a Powerbook G4.For phones and smartphones the regulation refers back to 2023/1670 where in B/1.1/1/c/ii it says:QuoteAll of section B relates. An individual user is still entitled to purchase parts to use in repair, and I think is allowed to make use of information on repair process supplied by other people.I did not try to read all of it in detail.

author: mtwieg
author_rank: Frequent Contributor
timestamp: September 23, 2025, 01:35:47 pm
content: There's a lot of nuance to the regulations, as usual. Not all batteries have to be replaceable by end users.The regulation defines five broad battery types: Portable, SLI, LMT, EV, and industrial. I believe the requirement for replaceability by end users applies only to portable types (I think this kicks in February 2027).But even for portable types, that requirement is not absolute. For example:Quote

author: Hydrochloride
author_rank: Contributor
timestamp: September 23, 2025, 02:54:21 pm
content: ...is here anybody that heared about that? wording of this regulation is ... battery has to be readily removable and replaceable by the end-user at any time during the lifetime of the product.First you need to know in which "battery type" your product falls. SLI, EV, portable, LMT or Industrial.Battery removability is only for portable (mostly small batteries for commercial products; like phones, laptops, tools...) and LMT(light motion transport. likely scooters and other things for traction).Adding this flyer from RLG that was quite useful when I had to check the regulation too.Depending on which category your product falls into, more or less work may be required. In my case, the product was classified as industrial, so I had to request a chemical test for Hg, Cd, and Pb (mg/kg), similar to a RoHS test. Had to redo the labeling to include additional information and a QR code (no battery passport, thank God!), and get in contact with a consultant to handle the due diligence part. Also having a local company to handle the battery waste from production.Fortunately, my battery is already removable. But from what I read, industrial batteries appear to be exempt from Article 11, so that part didn’t apply.

author: UglyKidJoe
author_rank: Newbie
timestamp: September 25, 2025, 03:33:47 am
content: Thank you for all your replies.The company I am workink for is producing customer products and due to the urgency we contacted the european union viahttps://european-union.europa.eu/contact-eu/write-us_en. We are dealing with portable batteries mainly fixed build in our products.We could get the info taht power banks are considered as battery by itself which is great.But all our other products are not falling into the exceptions categories (hygene, safety (can't be disconnected) or explosion environments) and we do not want to rely on independent professionals. We do not do mobile phones where at any corner ther is a shop repairing these...So we guess we have to redesign.

author: mtwieg
author_rank: Frequent Contributor
timestamp: September 25, 2025, 01:08:27 pm
content: Make sure you ask them exactly when the relevant rules come into effect, and what testing/paperwork/labeling is required. Also could ask them about penalties for nonconformance...This is going to create headaches for a lot of people and businesses, no doubt. I bet we're going to see a lot of devices redesigned as spashproof/waterproof, just as a way around it.

author: UglyKidJoe
author_rank: Newbie
timestamp: September 29, 2025, 02:00:04 pm
content: Careful, from what I understand it is not possible just to say "oh our product is IP67".There are enough examples that demonstrate it is possible to achive IP67 and the battery is replaceable.To ensure the safety of end-users, this Regulation should provide for a limited derogation for portable batteries from the removability and replaceability requirements set for portable batteries concerning appliances that incorporate portable batteries and that are specifically designed to be used, for the majority of the active service of the appliance, in an environment that is regularly subject to splashing water, water streams or water immersion and that are intended to be washable or rinseable.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.Where the derogation applies, the product should be designed in such a way as to make the battery removable and replaceable only by independent professionals, and not by end-users.