Actors already building a circular economy for batteries in Europe, i.e., repairers, refurbishers and recyclers, alongside environmental NGOs, call on the European Commission, Parliament and Council to adopt ambitious requirements in the Battery Regulation to enable battery removal, replacement and repair for consumer electronics and LEVs.

Removable, replaceable, and repairable batteries are an essential element of the battery regulation in order to support value retention and circularity, reduce EU dependency on critical raw materials, reduce e-waste and unnecessary consumption, as well as supporting worker safety and fire prevention.

EuRIC calls upon policy makers to set ambitious removability, replaceability and repairability requirements in Article 11 of the battery regulation:

Scope: the scope for these removability requirements should cover all consumer electronics. Light means of transport (e.g., e-bikes and e-scooters) should also be included in the scope. Removal and replacement for all: battery removal and replacement should be enabled for both independent professionals and end users. Enabling removal and replacement by citizens is essential for battery recovery and extending the life of electronics. Battery removal should be possible with no tools at all, or commonly available tools (i.e., with respect to EN 45554:2020).

Battery repair and repurposing for professional repairers: as well as removability and replaceability, battery repair should be enabled for independent professionals. The Commission is encouraged to start a standardisation process for cell level repair and repurposing.

Batteries as spare parts: quality battery packs should be available to end users as spare parts for at least the expected lifetime of the device. The components of the battery packs (e.g., cells, casing,board/BMS) should be available to independent professionals. Clear replacement and repair instructions should be freely available to end users and independent operators respectively to ensure safe battery management.

Software: battery software should not be a barrier to battery replacement or repair. Updates and serialisation should not prevent or discourage replacement by end-users, and independent operators should be able to manage the BMS to restore batteries they repair or repurpose.

Derogations: it is foreseeable that there are justifiable cases for exemptions for these requirements (e.g.,for medical devices) however any derogation should not present a loophole for manufacturers. Overall, single use, unrecoverable applications such as “printed batteries” should be reserved for essential applications.

2021.12.06 – RTR Final Report 2021