European Commission opens public consultation on delegated act to add product exemptions from portable battery removability/replaceability requirements

The European Commission launched a public consultation on a draft delegated act under Regulation (EU) 2023/1542 that would add additional product categories to the list of exemptions from the general requirement that portable batteries incorporated into products be removable and replaceable by consumers. If adopted, products in the newly exempted categories could shift from consumer removability/replaceability to professional-only removal/replaceability, impacting product design choices, user instructions, technical documentation and conformity strategies for manufacturers and importers. The Commission’s consultation also signals that related removability/replaceability guidance may be updated to reflect any new derogations. Feedback is requested by 26 May 2026 (deadline referenced in the research text).