Battery design for user replacement
Supplier guide for products with built-in portable batteries. This page explains how future products should be designed so the battery can be removed and replaced by the end-user under Regulation (EU) 2023/1542, Article 11.
Review current product design
Check whether the battery is glued, welded, soldered, sealed inside the housing, or otherwise inaccessible without damage.
Design for access and replacement
Use a serviceable battery compartment, commercial tools, connector-style wiring, safe insulation, and clear instructions.
EU market expectation
Non-compliant sealed designs create approval risk for products with built-in portable batteries.
Design direction we expect
- Battery can be reached with commercially available tools such as a screwdriver.
- If a special tool is unavoidable, it is supplied free of charge with the product.
- Battery is connected with a plug, socket, battery holder, or replaceable pack interface.
- Opening and replacement do not damage the product, battery, seals, PCB, or wiring.
- Manual and online page explain safe use, removal, replacement, and disposal.
Designs that must be avoided
- Battery permanently glued into the housing or fixed with adhesive that requires solvent or heat.
- Ultrasonic-welded or fully sealed housing that prevents battery access.
- Battery leads soldered directly to the PCB where the end-user replacement path requires soldering.
- Proprietary opening method without a supplied tool.
- Replacement process that breaks clips, destroys seals, bends the PCB, or damages the cell.
Supplier design checklist
| Design item | Acceptable approach | Not acceptable / high risk |
|---|---|---|
| Housing access | Screws, reusable clips, removable cover, service door, or free supplied tool. | Permanent welded shell or destructive opening. |
| Battery fixing | Holder, bracket, light removable tape, replaceable battery pack. | Glue requiring heat, solvent, cutting, or force that damages the product. |
| Electrical connection | Connector, spring contacts, plug lead, protected terminal design. | Soldering required during normal end-user replacement. |
| Replacement safety | Polarity marking, compatible replacement type, insulation, no short-circuit exposure. | No battery type, no polarity mark, exposed live contacts, unclear safety steps. |
| Instructions | Printed/manual instruction plus permanently available public online instruction. | No removal/replacement instruction or only internal factory notes. |
Short text for suppliers
This text can be copied into supplier communication. It is rewritten as a practical requirement, not copied from the attached example letter.
For any product supplied to Mega Step that contains a built-in portable battery, please review the mechanical and electrical design now...
Limited exceptions
- Washable or rinseable appliances designed primarily for regular splashing water, water jets, or immersion, where the exception is needed for user and appliance safety.
- Professional medical imaging and radiotherapy devices.
- In vitro diagnostic medical devices.
- Cases where power continuity and a permanent connection are required for user/appliance safety.
- Products whose main function is data collection and supply, where power interruption would compromise data integrity.
- Any claimed exception must be justified by design evidence, not by convenience or cost.
Legal reference
This page is based on Regulation (EU) 2023/1542 Article 11 and the Commission guidance on removability and replaceability. Use the official links for final legal checks.