The act everyone read as a reprieve
On 14 July the European Commission adopted a delegated act, and within a day the coverage had settled on a single word: exempt. Smartwatches, fitness trackers and smart glasses, the reports said, would not have to carry a battery a customer can change. Sealed designs were safe.
That is not what the act does. The obligation did not disappear. It changed hands, and the hands it changed to are ones an owner ends up paying for.
What Article 11 actually says
Article 11 of Regulation (EU) 2023/1542 applies from 18 February 2027. It requires that a portable battery incorporated in a product be readily removable and replaceable by the end user at any time during the life of the product, using commercially available tools, with no proprietary or specialised equipment involved.
The regulation already carried narrow derogations before this month. Appliances designed for wet environments, and certain medical devices covered by Regulations (EU) 2017/745 and 2017/746, sit in a different lane: the battery still has to come out, but an independent professional is the one who takes it out.
Six categories, one transfer of duty
The 14 July act adds six categories to that second lane. They are wearable devices, which the Commission takes to mean smartwatches, fitness trackers, smart glasses and anything integrated into clothing; certain medical devices; electronic toys; portable thermometers; roof-mounted telematics devices; and equipment falling under the rules for explosive atmospheres.
None of them leaves the regulation. A manufacturer selling into the EU must still make the battery removable and replaceable with commercially available tools. What changes is who is entitled to do it, and an independent professional is neither the end user nor, automatically, the manufacturer's own service desk.
The rule is not law yet
A delegated act is not finished when the Commission adopts it. This one was transmitted to the European Parliament and the Council for scrutiny, and it enters into force 20 days after publication in the Official Journal only if neither of them objects. Right to Repair Europe has already put its feedback on the Article 11 derogations on the record.
Our read, and no source draws it: procurement decisions being taken this month are resting on an instrument that can still be objected to. The date that has actually been fixed since 2023, and that nothing this month moved, is 18 February 2027.
What to put in the next contract
If you run a fleet of anything on that list, and plenty of European operators do without thinking of it as a fleet, the compliance route after February 2027 is a professional replacement channel. Field-service wearables, roof-mounted telematics on vans, handhelds rated for explosive atmospheres, clinical thermometers: all of them now depend on somebody being available to open the case.
Three lines in the next contract settle it. Name the independent-professional channel. State the per-unit battery replacement cost. State the turnaround. A vendor that cannot answer those is quoting you a device with an unpriced service tail attached.
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