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.

Now

Review current product design

Check whether the battery is glued, welded, soldered, sealed inside the housing, or otherwise inaccessible without damage.

New developments

Design for access and replacement

Use a serviceable battery compartment, commercial tools, connector-style wiring, safe insulation, and clear instructions.

18 February 2027

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. The battery must not be permanently sealed, glued, welded, or soldered in a way that prevents end-user removal and replacement. Please redesign affected products with a removable access cover, standard-tool opening method, connector-style battery interface, safe insulation, clear polarity marking, and public instructions for safe battery removal and replacement. If you believe an exemption applies, provide a written technical justification with product type, IP/water exposure need, safety reason, and proposed professional replacement method.

Limited exceptions

May move to independent professional replacement
  • 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.
May be outside the end-user rule
  • 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.
Do not use “waterproof”, “small product”, or “nice appearance” as a general reason for a sealed battery. The exception is narrow and must be documented.

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.

Regulation (EU) 2023/1542, Article 11 Commission guidance C/2025/214
Supplier-facing design guide. Final product decisions should be checked against the latest consolidated legal text and product-specific safety requirements.