Is the EU Batteries Regulation Charging Up for Trouble?

Main takeaways

1. The EU Batteries Regulation risks directly threatening product-design innovation, an area where Europe has always excelled
2. Beyond the economic impact, the mandate for end-user removable batteries introduces substantial safety and environmental risks
3. The push for battery removability may paradoxically increase waste from electronic devices

Global battery demand is experiencing an unprecedented surge, partly due to the growing shift towards more sustainable, battery-powered products – such as electric cars and bicycles, but also large-scale industrial energy storage systems. However, this exponential growth also brings considerable economic, environmental, and social challenges. 

That’s where the European Union stepped in. To address these challenges, it adopted a new Batteries Regulation for both battery-powered products and the raw materials used in their production – and rightly so. But while those efforts are laudable, one provision in particular risks causing more harm than good if implementation goes awry in the coming months. That is Article 11, which is meant to make it easier to remove and replace batteries from the majority of our electronic devices.

As the European Commission is currently assessing requests for critical exemptions to this rule; the future design, availability, and safety of everyday items (like smartphones, wireless earbuds, innovative smart glasses, but even your cordless vacuum cleaner) are being shaped right now.

1. EU Battery-removability rules 101 

For many device manufacturers, Article 11 stands out as one of the most challenging provisions. It requires that, from 18 February 2027, all portable batteries in devices sold on the EU market must be “readily” removable and replaceable by consumers with basic, commercially available tools. This requirement aims to extend product lifespans and facilitate recycling. 

Recognising that this may not always be feasible – especially for compact or sealed products – the Regulation allows for specific derogations. In January this year, the Commission launched a call for applications for specific exemptions that would allow battery replacements by third-party professionals instead of end-users. Many advocate that these exemptions should also cover devices like smartphones, wearables, and other portable consumer electronics, where strict adherence to the rule could increase safety risks or lead to more waste. 

With the application window now closed, the Commission is expected to assess submissions by autumn 2025. If justified, exemptions will be implemented through secondary EU legislation by early 2026.

2. European innovation at risk 

For certain products, batteries are placed to maximise space efficiency, waterproofing, thermal management, and structural durability. Think about your smartphone, wireless earbuds, handheld vacuum cleaner, or your child’s robot dog. The same goes for high-technology products such as smart glasses and other head-worn or wrist-worn wearables. 

Requiring such batteries to be accessible to consumers would necessitate bulkier, less durable designs that conflict with consumer demand for sleek, lightweight, and robust designs. Technologies like flexible printed circuit boards and 3D component stacking, essential for optimising limited internal volume, are incompatible with modular battery compartments. As a result, this replaceability requirement would hamper product innovation, especially in miniaturisation and elegant design – areas where Europe actually is a global leader, with companies like EssilorLuxottica, Polar, Withings, Bang & Olufsen, Devialet, Oura, and so many other established and promising brands.

What’s more, diverging from global standards by mandating EU-specific product variants increases design, manufacturing, and certification costs. A cost ultimately borne by consumers. Companies would be forced to create separate designs for the EU to comply with the battery-removability requirement. This regulatory fragmentation could discourage manufacturers from prioritising the EU market, potentially delaying access to innovative technologies for European consumers. 

The cumulative burden of complex EU regulations is already a hot topic in Brussels, and requirements like these may further hinder the EU’s ability to foster digital champions.

3. The environmental downsides of DIY battery swaps

It may seem counterintuitive, but the push to make batteries easily replaceable could actually lead to more waste, counteracting the EU’s efforts to reduce the amount of waste from electrical and electronic equipment, and the transformation of the European economy from a linear model to a circular one.

Small batteries in high-tech devices tend to degrade over time, even when not in use. This means manufacturers would need to build, package, and store (and later possibly discard) large numbers of replacement batteries – many of which may never be used, as too few consumers will actually seek repair. That alone is bound to increase the overall environmental footprint of these devices.

And despite the EU’s aspirations, recovery rates for electronic waste remain relatively low, with only 40.1% collected in 2022. Increased do-it-yourself swaps could further depress recovery rates for proper recycling. Additionally, the small size and low mass of batteries in high-tech devices – like digital cameras or smart glasses – make material recovery inefficient and costly compared to larger batteries for electric vehicles. This increases the likelihood of downcycling or landfill disposal, the last resort in the waste hierarchy. 

Conclusion: Navigating the trade-offs

The EU Batteries Regulation is an ambitious and essential step towards a sustainable and circular economy for batteries. Provisions like Article 11, however, reveal the complex trade-offs inherent in such sweeping legislation. While the intent to prolong product life and boost recycling is commendable, concerns about negative impacts on innovation, competitiveness, and user safety are widely shared by manufacturers, tech companies, and industry groups alike. 

As the Commission reviews the recent round of derogation requests, the spotlight will remain firmly on how this rule is implemented. Some Members of the European Parliament are already advocating for a more balanced regulatory approach – one that protects innovation and competitiveness, while still upholding environmental goals. 

The choices made in the coming months will determine whether Article 11 of the Batteries Regulation becomes a benchmark for balanced regulation, or a cautionary tale of overreach in the name of sustainability.