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Batteries - Removability and replaceability



Batteries and accumulators play an essential role to ensure that many daily-used products, appliances and services work properly, constituting an indispensable energy source in our society. On 10 December 2020, the Commission proposed a new Batteries Regulation, which aims to ensure that batteries placed in the EU market are sustainable and safe throughout their entire life cycle.

Given that a large majority of batteries are removed manually, non-removability poses challenges to sorting and increases recycling costs, subsequently reducing the material recovery from battery specific resources and a significant loss of resources to the EU. In turn, non-replaceability can limit the service life of appliances containing the batteries if the durability of the product and the longevity of the battery are not aligned. In such cases, a battery malfunction may lead to product replacement, and material loss.

In order to address the aforementioned challenges, the Commission’s proposal foresees in Article 11 that portable batteries incorporated in appliances shall be readily removable and replaceable by the end-user or by independent operators during the lifetime of the appliance. This provision not only ensures that portable batteries incorporated into appliances are subject to proper separate collection, treatment and high quality recycling once they have become waste, but it also enables the prolongation of the expected lifetime of the appliances whose batteries are part of.

The main objective of this project led by JRC is to facilitate the preparation of guidance on removability and replaceability of portable batteries, as requested by the Commission’s proposal. Such guidance would ensure that the provisions on portable battery removability and replaceability are applied equally and facilitate manufacturers in assessing whether the obligations are duly complied with.

Stakeholder involvement is a crucial part of this project. Consultation is foreseen with experts and stakeholders of battery and product manufacturers, member state representatives, consumer organizations, environmental NGOs and experts, with the view to hold discussions and develop consensus.