On 18 February 2027, Article 11 of the Battery Regulation takes effect. From that day, portable batteries must be removable and replaceable by the end-user with commercially available tools. Batteries for light means of transport (LMT), such as e-bikes, e-scooters and e-mopeds, must be replaceable by independent professionals, right down to cell level.
What this means for product design in concrete terms has been defined by the EU Joint Research Centre (JRC) in scientific work that underpins the Commission's guidance. The JRC has identified 15 parameters across 6 aspects that together determine whether a battery is easy to remove and replace in practice.
For manufacturers of everything from e-bikes to medical devices and consumer electronics, the JRC's 15 parameters are the most important design checklist right now. They do not just determine compliance. They determine whether the product can be placed on the European market at all after February 2027.
What does Article 11 require?
Article 11 sets two basic obligations, depending on the battery category:
Portable batteries (PB). Must be "readily removable and replaceable" by the end-user at any time during the product's life. Replacement must be possible with commercially available tools, without specialised tools (unless supplied free of charge with the product), without thermal energy and without solvents.
LMT batteries and individual cells in battery packs. Must be removable and replaceable by an independent professional, also at cell level. The obligation therefore covers not only whole battery packs, but also the individual cells inside them.
Both categories also require the manufacturer to make spare parts available for at least 5 years after the last unit has been placed on the market, and software must not prevent the use of compatible replacement batteries.
The regulation allows certain exemptions: products intended for wet environments, professional medical imaging and in vitro diagnostics can be designed so the battery can only be replaced by professionals. But the main rule has been tightened considerably compared with the current situation, where fewer than 10% of new smartphones have a user-replaceable battery.
How the JRC developed the 15 parameters
The JRC's method is published in a peer-reviewed scientific article (Magrini & Spiliotopoulos, 2026, Circular Economy and Sustainability) and serves as the basis for the Commission's practical guidance. The authors first identified all relevant parameters from the literature, existing standards (including EN 45554:2020 on repairability) and European legislation. The parameters were then assessed against three criteria:
- Verifiability: can market surveillance authorities test the parameter in a cost-effective way?
- Representativeness: does the parameter actually reflect the product's ease of disassembly in practice?
- Generality: can the parameter be applied across all portable and LMT batteries, not just specific product groups?
After consulting industry, NGOs and repair operators, the list was reduced to 15 parameters across 6 aspects. The selected parameters are either design-related (properties of the product itself) or service-related (conditions affecting repair after sale). This is a deliberate distinction: the circular economy is not only about how the product is built, but also about what happens to it afterwards.
The 6 aspects and what they mean for product design
Here are the 6 aspects under which the JRC has grouped the 15 parameters, what each covers, and which concrete design choices are at stake.
Tools for disassembly and reassembly
Which tools are needed? The JRC distinguishes between no tools, commercially available tools (screwdrivers, hex keys) and specialised tools. For portable batteries, Article 11 explicitly requires that ordinary tools are sufficient, or that the specialised tool is supplied free of charge with the product.
Design consequence: Proprietary screw types, adhesive that requires heating, or mechanisms that require factory jigs are effectively ruled out for consumer products after 2027.
Joining techniques and fasteners
How is the battery fixed in place? The JRC assesses fasteners on two dimensions: the type (screws, clips, magnets, adhesive, welds) and their reusability. Reusable fasteners, such as screws that can be screwed in and out several times, score high. Permanent adhesive or welds score low or disqualify.
Design consequence: Some current electronics designs use adhesive to fix the battery, because it allows thinner and more waterproof products. From 2027, adhesive must be replaced by mechanical fasteners or "pull-tab" solutions that allow non-destructive disassembly.
Information supplied with the product
What guidance comes with it? Article 11 requires the manufacturer to provide instructions and safety information on the use, removal and replacement of the battery, permanently available online, in a form that is easy for end-users to understand. The JRC's parameters cover, among other things, disassembly diagrams (exploded views), step-by-step guides, the safety equipment required during the process, and specifications for compatible replacement batteries.
Design consequence: Information is no longer a nice-to-have or something marketing controls. It is a compliance deliverable that must be versioned, maintained for at least 5 years after the last sale, and documented during market surveillance.
Availability of spare parts at a reasonable price
How easy is it to get a new battery? The JRC looks at several parameters: availability through several channels (manufacturer, retailers, independent repairers, end-users), delivery time, and price relative to the price of a new product. A battery that costs 80% of a new product effectively rules out replacement as a realistic choice.
Design consequence: Spare parts logistics must be planned 5+ years ahead from the product's last year of production. Manufacturers working with short product cycles today must set up long-term stocks or production capacity for batteries that would otherwise be phased out.
Disassembly depth
How many steps does it take to reach the battery? Disassembly depth (DD) counts all steps in the process, not only how many parts are removed, but also tool changes and separate actions. The JRC's reference scoring system gives the top score at 2 steps or fewer, and lower scores at 5, 10 and 15 steps.
Design consequence: The battery should be accessible as early as possible in the disassembly sequence. For many products, this means a fundamental rethink of the component layout: the battery can no longer sit at the back of a sandwich construction behind the circuit board, screen and speaker.
Software restrictions that prevent replacement
Does software prevent the use of third-party or compatible batteries? A growing phenomenon is "part pairing", where a serialised component only works fully if it is paired with the device via the manufacturer's software. For batteries, this can mean that a new, compatible battery has reduced performance or shows warnings if it has not been approved by the manufacturer. Article 11 prohibits this practice when it prevents replacement with compatible alternatives.
Design consequence: Battery management systems may identify compatibility, but must not actively block or degrade the functionality of a battery that meets the technical specifications. Existing firmware must be reviewed for hidden restrictions.
Why 6 aspects and not just one rule?
The JRC's approach is deliberately multi-dimensional, because a single parameter cannot capture reality. A battery can be fixed with two screws (perfect fastening) but sit behind 12 other components (poor disassembly depth). It can be easy to remove (good design) but impossible to obtain as a spare part (poor service). It can be cheap to produce (good for the margin) but expensive to sell as a spare part (bad for compliance).
The 6 aspects are designed to work together. A score in one area cannot compensate for another. A product must perform acceptably on all 6 aspects to meet Article 11: it is a multi-dimensional threshold, not an average.
For manufacturers, this means that compliance cannot go through one single design team. Mechanical engineers own aspects 1, 2 and 5. Software and firmware teams own aspect 6. The service and aftermarket function owns aspects 3 and 4. A single owner of battery passport compliance needs to coordinate across them.
What does it have to do with the battery passport?
Many of the 15 parameters reappear as data points in the digital battery passport, which becomes mandatory on the same day: 18 February 2027. The passport must contain:
- Disassembly instructions and exploded views
- Specifications for compatible replacement batteries
- Information on which tools are required
- Safety information during the disassembly process
- Access to software tools or firmware needed for full functionality after replacement
This means that compliance with Article 11 and compliance with the battery passport are two sides of the same coin. The documentation that demonstrates removability is the same documentation that sits in the passport. Manufacturers that build the battery passport structure now are at the same time laying the foundation for the Article 11 documentation.
The timeline and why 2026 is decisive
Article 11 takes effect on 18 February 2027. It sounds as if there is time, but for most hardware manufacturers it is already close.
- Design cycles for electronics: Typically 18-24 months from concept to shelf. A product launched in February 2027 is already in the design phase now.
- Tooling investment: Injection moulds and press tools must be redesigned to support mechanical fasteners rather than adhesive. It is not a software update. It is capital investment.
- Spare parts logistics: A 5-year supply guarantee after the last production means that logistics, warehousing and purchasing functions must set up processes well before the first launch under the new regime.
- Documentation: Disassembly instructions, exploded views, compatibility specifications and battery passport data must be structured, validated and published for each product variant.
Manufacturers that wait until mid-2026 to address Article 11 will probably be forced to withdraw product variants from the European market, because the design cannot be changed in the time left. It is not a compliance fine. It is a loss of market access in the EU, and therefore a direct threat to 2027 revenue.
What you can do now
For manufacturers with battery-powered products, four steps are worth taking already:
- Audit your existing products against the 6 aspects. Which products score poorly on disassembly depth, fastening or information quality? Those are the ones that need design changes before 2027.
- Map your software for hidden restrictions. Part pairing, battery locking or firmware that degrades functionality with third-party batteries must be identified and removed.
- Set up a spare parts plan with a 5+ year horizon. Production, warehousing and purchasing must be able to guarantee batteries for 5 years after the last sale.
- Structure the documentation so it covers both Article 11 and the battery passport. Disassembly instructions, compatibility specifications and safety information are overlapping requirements: build them once, use them in two places.
Manufacturers that use 2026 to take these steps will have a considerable advantage when their competitors have to rush designs in the fourth quarter and the first quarter of 2027.
