Our members drive innovation in battery-powered devices and empower consumers to participate in the circular economy by providing transparent sustainability information about products, facilitating access to repair, offering trade-in programmes and refurbished products.
We support the initial European Commission’s proposal which would ensure battery replaceability without compromising safety or the sector’s innovative capacity. We are concerned that the Parliament’s position on the replaceability of portable batteries could endanger the safety of consumers and inhibit innovation in the ICT sector.
Safety: We recommend that battery replacement be performed either by a qualified operator or end-user, as foreseen in the original Commission text. This will ensure that skilled operators carry out battery replacement where there are safety risks (e.g. fire, explosion) associated with inappropriate replacement. The Parliament requires that all portable batteries be replaceable by end-users. Our products are complex, and end-user replacement might not always be suitable due to safety concerns.
Innovation: We believe the request to ensure tools are available to enable a repair is fair. However, the Parliament requires that all portable batteries be replaceable using ‘basic tools’, which is a very restrictive list of tools that could prevent future innovations on the tooling and the design sides of devices. We, therefore, recommend that replacement should occur with publicly or commercially available tools.
Implementation: The Parliament wants the new rules to apply as of January 1st 2024. The proposed Regulation will have far-reaching impacts on the design, labelling and end-of-life of battery-powered products, which will require time to implement. We, therefore, recommend a minimum 24-month transition period.