Battery Removability and Replaceability

In December 2021, EERA joined repairers, refurbishers, recyclers and environmental organisations in calling for stronger requirements on the removability, replaceability and repairability of batteries in consumer electronics and light means of transport. The joint statement addressed the European Commission, European Parliament and Council during negotiations on the proposed EU Batteries Regulation.

The signatories called for battery design requirements that would support longer product lifetimes, improve battery recovery and recycling, reduce unnecessary electronic waste and contribute to the more efficient use of critical raw materials such as lithium and cobalt. They also highlighted the implications of integrated batteries for worker safety and fire prevention in the recycling sector.

The joint statement set out recommendations for Article 11 of the proposed Batteries Regulation, covering battery removal and replacement, professional repair and repurposing, access to spare parts and repair information, software restrictions and narrowly defined derogations.

Why battery removability and replaceability matter

The joint statement identified integrated batteries as a barrier to longer product lifetimes and greater circularity. It noted that batteries in many portable electronic products were glued or soldered into devices, requiring specialist tools, additional time and technical knowledge for safe removal.

When batteries are difficult to remove or replace, a failing battery can shorten the useful life of an otherwise functioning product. The statement also highlighted barriers such as limited access to replacement batteries, appropriate tools and repair information. In battery packs, difficulty accessing individual cells can result in the disposal of the entire pack even where some cells could potentially be repurposed.

The statement also addressed batteries used in light means of transport, including e-bikes and e-scooters. While removable and replaceable battery packs were becoming increasingly common, the design of some packs made cell-level repair difficult or unsafe. The signatories also raised concerns about software restrictions that could prevent battery repair.

The signatories therefore called for battery removability, replaceability and repairability to form part of the Batteries Regulation, linking these requirements to product life extension, battery recovery, reduced e-waste and more efficient use of critical raw materials.

Implications for recycling and fire safety

The joint statement linked battery design directly to recycling efficiency and worker safety. Integrated batteries can be difficult to identify and remove before treatment, particularly when they are glued, soldered or connected using proprietary components. The additional time and specialist tools required can also increase operational costs for sorting and recycling facilities.

When lithium-ion batteries remain inside discarded products, they can be damaged during collection, sorting or treatment. The statement highlighted the increasing number of battery-related fires reported by WEEE management facilities and noted that batteries discarded in other waste streams can also cause thermal incidents across the wider recycling sector.

These incidents can damage facilities, disrupt operations and create risks for workers. The statement also drew attention to the implications for insurance coverage, identifying the increasing frequency of lithium-ion battery incidents as a growing concern for waste operators.

The signatories therefore connected improved battery removability not only with repair and product life extension, but also with safer end-of-life treatment and more effective battery recovery.

What the joint statement called for

The joint statement called on EU policymakers to introduce ambitious removability, replaceability and repairability requirements under Article 11 of the proposed Batteries Regulation.

The signatories called for:

• Broad product coverage: removability requirements should apply to all consumer electronics and include light means of transport such as e-bikes and e-scooters.

• Removal and replacement by end users and independent professionals: batteries should be removable and replaceable without tools or with commonly available tools, supporting both battery recovery and longer product lifetimes.

• Professional battery repair and repurposing: independent professionals should be able to repair batteries, with a standardisation process developed for cell-level repair and repurposing.

• Access to spare parts and information: replacement battery packs should remain available to end users for at least the expected lifetime of the device, while independent professionals should have access to battery components and appropriate repair information.

• No software barriers: software updates, serialisation and battery management systems should not prevent or discourage battery replacement, repair or repurposing.

• Narrowly defined derogations: exemptions may be justified for certain applications, such as medical devices, but should not create loopholes that undermine the wider requirements.

Together, these recommendations sought to ensure that battery design supported repair, reuse and recycling throughout the product lifecycle rather than creating barriers once a battery or product required replacement or reached end of life.

Battery repair and access to spare parts

The joint statement called for battery circularity requirements to extend beyond removal and replacement to include repair and repurposing by independent professionals. It recommended that the European Commission initiate a standardisation process for cell-level battery repair and repurposing.

Access to replacement batteries was another priority. The signatories called for quality battery packs to remain available as spare parts for at least the expected lifetime of the device, enabling users to replace a battery rather than discard an otherwise functional product.

For professional repairers, the statement called for access to individual battery-pack components, including cells, casings and battery management system (BMS) boards. It also called for clear replacement instructions to be freely available to end users and repair information to independent professionals to support safe battery management.

These recommendations addressed situations where the inability to obtain a replacement battery or repair an existing battery pack could result in the premature disposal of the battery or the entire product.

Software and barriers to repair

The joint statement called for software not to prevent or discourage battery replacement and repair. It specifically identified software updates and serialisation as potential barriers where they restrict the replacement of batteries by end users or independent professionals.

For battery repair and repurposing, the signatories also called for independent professionals to have the ability to manage the battery management system (BMS) so that repaired or repurposed batteries could be restored to operation.

The statement therefore treated access to software functionality alongside physical access to batteries, spare parts and repair information as part of enabling effective battery replacement, repair and repurposing.

Derogations

The joint statement recognised that limited exemptions from battery removability, replaceability and repairability requirements may be justified for certain applications, citing medical devices as an example. However, the signatories called for any derogations to be narrowly defined so that they did not create loopholes that could undermine the wider requirements.

The statement also addressed single-use applications in which batteries cannot be recovered, including printed batteries. It called for such applications to be restricted to essential uses.

Key messages

• The joint statement called for removable, replaceable and repairable batteries to support longer product lifetimes, battery recovery and recycling, and reduced electronic waste.

• Battery removability and replacement requirements should cover consumer electronics and light means of transport, including e-bikes and e-scooters.

• End users and independent professionals should be able to remove and replace batteries, while professional repairers should also be able to repair and repurpose battery packs.

• Replacement batteries, components and appropriate repair information should remain available to support safe replacement and repair throughout the expected lifetime of products.

• Software and serialisation should not create barriers to battery replacement, repair or repurposing.

• Any derogations should be limited and clearly justified, avoiding exemptions that could undermine the wider requirements.

  About the joint statement

  Published on 6 December 2021, the joint statement brought together repairers, refurbishers, recyclers, environmental NGOs and other circular economy stakeholders calling for stronger battery removability, replaceability and repairability requirements in the proposed EU Batteries Regulation.

  EERA was among the organisations supporting the statement, alongside the European Environmental Bureau (EEB), EuRIC, Right to Repair Europe, RREUSE, Transport & Environment, Umicore and Zero Waste Europe, as well as companies and other organisations active in battery repair, refurbishment and reuse.

  Together, the supporting organisations represented around 500 companies, social economy actors and NGOs working towards a more circular economy for batteries.

Read the joint statement

Read the full joint statement Europe’s circular economy leaders demand removable, replaceable, and repairable batteries, including the complete policy recommendations and list of supporting organisations

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