
In 2022, the EU introduced new legislation aimed at reintroducing user-replaceable batteries in electronic devices, set to take effect in February 2027. Notably, some companies, like Nintendo, have already embraced this change by launching a special Switch 2 with a replaceable battery.
However, concerns arose regarding how replaceable batteries might impact features like water resistance. In response, the EU has designated several exemptions for specific device categories.
A key category includes what are termed “wet appliances.” These devices encompass “wearable devices, such as wireless earbuds, heart rate monitor straps, smart glasses or watches, as well as outdoor wireless speakers.”
Several device categories are now exempt from the EU’s replaceable battery standards
Wet appliances are those engineered to operate primarily in environments prone to splashes, submersion, or those intended for washing. While electric toothbrushes clearly fall into this category, it may be less obvious when considering outdoor wireless speakers.
For smaller devices like wearables, exemptions may apply “based on considerations related to miniaturisation.” This is particularly relevant for designs with tightly packed internals, posing a risk of user injury while attempting to replace a battery—particularly with lithium batteries. As such, these batteries should only be replaced by professionals.
The European Commission has stated that it may introduce additional exemptions for new device categories as “market developments and technical and scientific progress” evolve. The complete legislation can be accessed here (PDF).
It's essential to clarify that “user-replaceable batteries” does not imply that users can replace them without tools, as was common with older phones. Rather, battery replacement should be achievable with basic tools, like a screwdriver and a pry tool.

Additionally, a specific exemption applies to phones, which must have at least an IP67 rating. The battery should retain at least 83% of its original capacity after 500 charge cycles, or a minimum of 80% after 1,000 cycles. For such devices, battery replacement may only be performed by professionals. This exemption covers many modern flagship and mid-range smartphones, leading to anticipation regarding the impact of the new regulations in the coming year.
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