Joint position paper on removability and replaceability of portable batteries

As the European Parliament is preparing to define its position on the Batteries Regulation proposal, TIE together with 10 European associations are sharing their recommendations for a safe battery replaceability.

The associations support the European Commission proposal to enable battery replaceability as a way to extend the durability of electrical products and to promote circularity. Innovation is crucial for Europe’s competitiveness and too strict rules and design requirements could discourage any investment by European companies in new products or technologies. There is also a wide variety of appliances, including a wide range of toys, that work with portable batteries. A one-size-fit-all approach on replaceability can in some cases be counterproductive from a sustainability point of view.

That is why we issue a range of recommendations on Article 11 of the Batteries Regulation proposal to achieve battery replaceability without compromising on consumer safety and functionality of products:

  1. Battery replacement should 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 be possible with publicly or commercially available tools;
  5. Replacement should not cause permanent damage;
  6. Software must still be allowed to prevent safety incidents and thermal events.

Download the full Joint Paper on Batteries Draft Regulation Art. 11