Article 11 of Regulation (EU) 2023/1542 requires portable and LMT batteries to be removable and replaceable, a rule that reshapes device design and battery-pack interfaces. It applies from 18 February 2027, and Commission guidelines issued and updated in spring 2026 — followed by an adopted revision on 14 July 2026 — expanded the exemption list from two to eight product categories. This paper explains the rule, the professional-replacement route and what it means for nickel-metal hydride (NiMH) pack suppliers.
From 18 February 2027, appliances incorporating portable batteries must be designed so an end user can readily remove and replace them: removal with commercially available tools (or no tools), without damaging the appliance, and with replacement instructions and safety information permanently available. Devices must not be designed so device lifetime is bound to battery lifetime, and manufacturers must make spare batteries and replacement parts available for at least five years after the last unit is placed on the market; software may not block a compliant replacement battery of equivalent specification. LMT batteries follow a parallel but professional-workshop-oriented regime.
The April draft and the 14 July 2026 adopted revision expand the categories exempted from end-user removal to eight: devices designed for splash, water or dust ingress protection (IP-rated sealed appliances), devices operating in harsh environments, medical devices as defined by Regulation (EU) 2017/745 and in-vitro diagnostics under 2017/746, devices where continuous power is essential for safety or data integrity (with automatic backup), devices requiring special battery performance specifications, and the newly added wearables, electric toys and ATEX explosion-protected equipment. Exempted devices do not escape replaceability — they must instead be serviceable by independent professional repairers: replacement with common professional tooling, documented procedures and spare availability. Washable devices and professional medical imaging/radiotherapy equipment already follow the professional-only route in the base text.
NiMH chemistry is well aligned with the rule's intent. Standard cylindrical and prismatic NiMH cells are commodity replaceable formats (AA/AAA/C/D/9 V) with stable dimensions under IEC standards, and custom welded packs can be designed with connectors rather than welded-to-PCB construction, standardized holders and clearly labeled polarity. For exempted professional-service devices — sealed medical instruments, wearable monitors, ATEX sensors — NiMH packs can be specified as five-year service spares with documented disassembly torque, connector keying and replacement-procedure sheets. The requirement that software not lock out equivalent replacement batteries is trivially met by NiMH packs, which carry no cryptographic battery-authentication chip.
Manufacturers must keep replacement batteries available for at least five years after the last appliance unit is sold, and offer them through accessible channels. For an OEM this means its cell supplier must guarantee form-fit-function availability of the NiMH cells and packs for a comparable horizon — a supply-continuity question as much as a legal one. It also means the replacement battery must itself carry full Article 13 labeling, a Declaration of Conformity and the same Annex III durability parameters; a "service spare" is not a compliance loophole.
Concrete actions for device programs: classify the appliance against the eight exemption categories and record the rationale; if non-exempt, adopt user-openable battery compartments with standard fasteners and no permanent bonding; if exempt, write the professional replacement procedure and list required tools; standardize on catalog NiMH formats or connectorized custom packs; publish removal/replacement instructions in the manual and online for the device lifetime; plan five-year spare stock with the cell supplier; and verify that no firmware check rejects third-party equivalent cells. Article 11 is a device-maker obligation, but auditors trace it straight to the battery supplier's documentation.
Weijiang Power supports Article 11-ready designs with standard IEC-format NiMH cells and connectorized custom packs, five-year form-fit-function supply agreements, labeled service-spare packs carrying full DoC and durability data, and replacement-procedure drawings for professional-service devices. Share your device category and enclosure design and we will confirm the exemption route and deliver the pack interface and documentation that make replacement lawful by February 2027.
