EU Battery Regulation: new exceptions for smartwatches and toys
From February 2027, batteries in many devices must generally be replaceable. However, the EU Commission is now expanding the exceptions. These include, among others, certain smartwatches, electric toys, and special medical devices.
The EU Battery Regulation aims to phase out permanently installed batteries and extend the lifespan of electronic devices. Now, the European Commission is extending the exemptions from the replacement obligation to six additional product groups.
These include certain wearables such as smartwatches and fitness trackers, electric toys, and several specialized medical, industrial, and agricultural devices. For these, manufacturers are allowed to install batteries in such a way that only independent specialists can remove and replace them. The Commission justifies the exemptions primarily with safety risks and special requirements for the size, sealing, or durability of the devices.
However, the obligation for users to replace batteries is not generally waived for every smartwatch or electric toy. The respective devices must meet the requirements set out in the delegated act.
Special rule for small and sealed wearables
For the electronics market, the exemption for wearables is particularly relevant. In addition to smartwatches and fitness trackers, it can also affect smart glasses and electronics in clothing or accessories.
The design is crucial. The Commission allows the exemption, for example, for particularly small devices where safe access to the battery is technically hardly possible. A permanently sealed casing can also justify it if it needs to protect the product from water, dust, or impacts.
This weakens a central provision of the Battery Regulation. As reported in 2023, portable batteries should generally be removable and replaceable with commercially available tools from February 18, 2027. Heat or solvents should not be necessary for this.
Toys receive a transitional rule
Electric toys can also fall under the new exemptions. A special rule applies to this point until July 31, 2030. After that, corresponding provisions of the new EU Toy Regulation will apply.
The Commission primarily wants to avoid risks for children. In small products, an accessible battery or parts of the closure could be swallowed. In such cases, manufacturers may continue to house the energy storage device securely within the casing.
Source: OMfotovideocontent / Shutterstock
In addition, there are devices for potentially explosive atmospheres. Depending on the area of application, these include specially protected motors, sensors, pumps, or industrial trucks. In these cases, intervention could impair the protective effect.
Body-worn systems for subcutaneous drug delivery are also covered. Incorrect replacement could affect their function or dosage. Another exception includes telematics devices on agricultural and construction machinery. They must withstand strong vibrations, dust, water, and temperature fluctuations. Their maintenance is usually carried out by trained specialists.
The sixth product group concerns wireless temperature probes for food. These include compact grill or meat thermometers that are inserted into food during cooking. If their seal is damaged during improper intervention, battery chemicals could come into contact with food.
Source: Dmitry Naumov / Shutterstock
The new special rules do not change the fact that the regulation already has consequences for product development. My colleague Michelle has analyzed in a detailed background how Nintendo, Apple, and other manufacturers are adapting their devices.
Exemptions already existed – also for smartphones
The Battery Regulation already contained special rules. These apply, among other things, to certain medical devices and to so-called wet devices that regularly come into contact with water and must be washable. These include electric toothbrushes and oral irrigators.
Smartphones and tablets, however, are not exempt solely because they are protected against water and dust. For them, the European Ecodesign requirements also apply. Under certain conditions, manufacturers may use particularly durable, permanently installed batteries. You can read more about this in my first article.
The EU does not always require a freely accessible energy storage device. The crucial point is that a worn-out battery can be replaced without having to dispose of the entire device.
Parliament and Council can still object
The Commission adopted the exemptions as a delegated act on July 14, 2026. Now, the European Parliament and the Council of the EU are reviewing the regulation. If neither body objects, it will enter into force 20 days after its publication in the Official Journal of the European Union.
Little changes regarding the fundamental goal of the Battery Regulation. The EU wants to facilitate repairs and avoid electronic waste. However, for small, sealed, or safety-critical devices, it now grants manufacturers even more leeway.
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