EU New Battery Law (EU) 2023/1542- Interpretation of Detachability and Replaceability

With the mandatory implementation of the EU's new battery law, the issue of disassembly and replaceability related to Article 11 is receiving increasing attention. The new battery regulations have put forward higher design requirements for battery production enterprises. Batteries in equipment should be able to be dismantled and replaced by end users or independent operators, ensuring that the service life of battery products can be extended to prevent unnecessary waste. At the same time, it is required to prove that the products are safe during normal operation and trial period.

In short, starting from 2027, all portable batteries should adopt a detachable battery design, allowing consumers to open their devices, remove or replace batteries without the need for special tools (such as solvents, heating) or training. All LMT batteries should be able to be easily disassembled and replaced by professionals (this article only discusses portable batteries).

Portable batteries should be ensured to be easily disassembled and replaced by end-users at any time during the product's lifespan. This requirement only applies to the entire battery and does not apply to individual batteries or other components included in such batteries. Instructions and safety information regarding the use, disassembly, and replacement of batteries should be permanently provided online on public websites in a way that is easy for end users to understand.

The specific regulatory requirements are as follows:

(1) Batteries can be disassembled and replaced by end-users at any time during the product lifecycle. The product should be accompanied by instructions for battery use, disassembly and replacement, as well as safety information, and permanently placed on public websites;

(2) Only applicable to the entire battery, not applicable to individual cells or other components included in the battery;

(3) The replacement does not affect the functionality, performance, and safety of the product;

(4) Within 5 years after the last product is launched on the market, backup batteries should be provided at a reasonable price;

(5) Exemption situation: batteries specifically designed for operation in water environments; Batteries for professional medical imaging and radiation therapy equipment; For safety or data integrity, continuously powered batteries are required.

Shenzhen Element Testing Co., Ltd. can draw conclusions based on the evaluation of dismantling tools, availability of backup batteries, dismantling information, dismantling depth/steps, and regulatory exemptions. Our company may be one of the few institutions in the industry that can provide this service.

1) Disassembly tools

Maintenance that does not require tools, repairs that can be carried out using basic tools, tools for specific product groups, other commercial tools, proprietary tools, and repairs that are not feasible with any tool.

2) Backup battery availability

- The availability of physical components required for battery replacement (excluding the backup battery itself).

The availability of software elements (and updates) that may be required for the normal operation of batteries introduced into the device.

3) Dismantling information

The following types of information are considered relevant information:

- disassembly or exploded view of battery disassembly, reassembly, and normal operation;

- Technical manual for disassembly and replacement instructions;

- Software tools, firmware, and similar auxiliary means required for all functions of the device after battery replacement;

- Ensure relevant information on the safe dismantling process, including technical specifications for compatible batteries or specifications for conducting quality replacement process testing. In any case, battery disassembly and replacement should be carried out in accordance with the safety information provided by the product manufacturer regarding battery use, disassembly, and replacement.

4) Dismantling depth/steps

The concept of disassembly depth refers to the number of steps required to remove parts from the product. For end user detachable batteries, this is an important factor in ensuring reasonable disassembly time.

5) Exemption situation

Article 11, Paragraph 2 stipulates that electrical appliances specifically designed for operation primarily in environments that are frequently exposed to splashing water, water flow, or water immersion, as well as appliances designed to be washable or washable, are not subject to the provisions of Paragraph 1, and are designed in such a way that batteries can only be dismantled and replaced by qualified independent professionals. As is well known, IP rating ranks the ability of the casing to resist dust or liquid intrusion. In general, the "splashing" situation mentioned in Article 11 can be regarded as equivalent to IPX4 level (level 4), the "water flow" situation can be regarded as equivalent to IPX5 and IPX6 level (level 5 and 6), and the "immersion" situation in regulations can be regarded as equivalent to IPX7 level (level 7).

Welcome to contact Shenzhen Element Testing Co., Ltd. for more information.