Joint position paper on removability and replaceability of portable batteries

Here are six recommendations to the European Parliament, on Article 11 of the Batteries Regulation, in order to achieve battery replaceability without compromising consumer safety, performance or innovative capacity of the sector.

The undersigned joint group of associations, would like to share their joint position on the removability and replaceability of portable batteries foreseen in the proposed Article 11 of the Batteries Regulation proposal. The topics addressed in this paper may also inform the current discussions in the European Parliament about similar requirements for Light Means of Transport batteries. Our members drive forward many of the innovations related to battery-containing devices, which will be crucial in the transition towards a circular economy. Throughout the legislative discussions, we have contributed our expertise to provide sound and feasible improvements to ensure the safety of consumers and safeguard innovation. 

The associations support the European Commission proposal to enable battery replaceability as a way to extend the durability of our electrical products. Based on decades of design experience and maintaining professional repair networks, we would like to share our insights on how to achieve the policy-makers’ objectives of ensuring battery replaceability without endangering consumer safety or the functionality of the appliance. 

As a general note, when referring to battery replacement we refer to the replacement of a complete battery. A complete battery includes all individual battery cells, necessary electronics as well as internal connectors and housing. The replacement of parts or individual battery cells within a battery pack is safety-critical and shall therefore not be enshrined in law.

That is why we issue the following recommendations on Article 11 to achieve battery replaceability without compromising on consumer safety, performance or innovative capacity of the sector:

 

  1. Battery replacement shall be performed either by qualified independent operators or end-users, as foreseen by the original Commission Proposal;
  2. An adequate transition time of at least 24 months for the application of obligations on replaceability;
  3. A defective battery must be replaced by an authorised technically identical battery;
  4. Replacement should occur with publicly or commercially available tools;
  5. Replacement should occur without causing permanent damage;
  6. Safety in software.

 

Download the full joint position paper