EU battery rules for small sellers: what changes on 18 February 2027

By Frank, founder of Keyhavn. Last checked 3 October 2026.

Short version. If you sell a product with a built-in battery in the EU under your own brand, then from 18 February 2027 the battery must be replaceable by the customer with ordinary tools, you must offer spare batteries for five years, and the battery needs a QR code. E-bike and e-scooter batteries also need a digital battery passport.

I wrote this because I sell wireless keyboards and found out late that these rules apply to me. Most of what I found online was written for car makers and large manufacturers. This page is the version I needed as a small seller. If you want to hear when something changes, leave your email at the bottom.

Does this apply to you?

Probably, if both of these are true:

You sell a product in the EU that contains a battery, for example a wireless keyboard or mouse, earbuds, a speaker, a power bank, a toy, an e-bike or an e-scooter.
You import it from outside the EU or sell it under your own brand. The regulation treats whoever first makes a battery available in an EU country as its producer, including when the battery is inside another product.

Selling through bol.com or Amazon doesn't move the responsibility to the marketplace.

Dates and obligations

Date	Obligation	Applies to
18 Aug 2024	CE marking, declaration of conformity, lead limit of 0.01%	All batteries
18 Aug 2025	Producer registration and collection fees in each EU country you sell into; crossed-out wheelie bin symbol	All batteries
18 Aug 2026*	Harmonised label with capacity, chemistry, category and manufacturer (Art. 13)	All batteries
18 Feb 2027	Battery removable and replaceable by the end user with commercially available tools (Art. 11)	Portable batteries in products
18 Feb 2027	Spare batteries available for 5 years after the last unit of a model is sold; removal instructions in print and online (Art. 11)	Portable batteries in products
18 Feb 2027	QR code printed or engraved on the battery (Art. 13)	All batteries
18 Feb 2027	Digital battery passport (Art. 77)	E-bike and e-scooter (LMT), EV, and industrial batteries over 2 kWh

* The labelling date depends on when the Commission's implementing act took effect and may fall later. Check before printing new labels.

Exemptions

In July 2026 the Commission adopted exemptions where only a professional needs to be able to replace the battery: certain sealed wearables, rechargeable toys (until 31 July 2030), wireless food thermometer probes, equipment for explosive atmospheres, on-body drug delivery devices and roof-mounted machinery telematics. Products that must stay waterproof and some medical devices have separate exemptions. Keyboards, mice, earbuds and speakers are not on the list.

What to do now

List every product you sell with a battery: battery type, chemistry, capacity and supplier.
Open one up. Check that a customer could swap the battery with a screwdriver and that it sits on a connector, not soldered or glued. If not, contact your factory now; design changes take months.
Ask your supplier for spare batteries and whether they can supply them for five years.
Check your producer registrations in every country you ship to.
Write replacement instructions and publish them at a permanent web address your QR code can point to.
If you sell e-bikes or e-scooters, ask your battery supplier who will create the passport and what data they will provide.

Updates