No, this is the adopted text. Its basically an update of the text you linked, which is the regulation from 2020. The relevant part you want might be (38) and (39):
(38) […] A portable battery should be considered to be removable by the end-user when it can be removed with the use of commercially available tools and without requiring the use of specialised tools, unless they are provided free of charge, or proprietary tools, thermal energy or solvents to disassemble it […]
(39) To ensure the safety of end-users, this Regulation should provide for a limited derogation for portable batteries from the removability and replaceability requirements set for portable batteries concerning appliances that incorporate portable batteries and that are specifically designed to be used, for the majority of the active service of the appliance, in an environment that is regularly subject to splashing water, water streams or water immersion and that are intended to be washable or rinseable. This derogation should only apply when it is not possible, by way of redesign of the appliance, to ensure the safety of the end-user and the safe continued use of the appliance after the end-user has correctly followed the instructions to remove and replace the battery. Where the derogation applies, the product should be designed in such a way as to make the battery removable and replaceable only by independent professionals, and not by end-users.
The evil is always in details, thats why with their Incandescent light bulb ban, these are now sold as heating devices/lamps, so much for their bans/rules. That’s why I pointed out commercially available tools can be at same time specialized tools, they should rather mention something like it must be tools owned by 50% households according stats and do simple survey about screwdrivers.
I’m going to be honest, I think that this is a case where companies will always dodge the rules unless the consequences are so severe they’re unwilling to risk it. Something like forced downsizing, or a fine proportional to annual revenue. That would make companies significantly more hesitant to try and tread the line.
Is this (article 11 on page 55) the approved text? It seems kind of vague on what constitutes “readily removable and replaceable.”
No, this is the adopted text. Its basically an update of the text you linked, which is the regulation from 2020. The relevant part you want might be (38) and (39):
It’s contradictory, what about commercially available specialized tools? Who defines what’s specialized and not?
I mean…you can be pedantic about it, but to me this reads fairly clearly as “If it can’t be removed with a screwdriver, it’s not allowed.”
The evil is always in details, thats why with their Incandescent light bulb ban, these are now sold as heating devices/lamps, so much for their bans/rules. That’s why I pointed out commercially available tools can be at same time specialized tools, they should rather mention something like it must be tools owned by 50% households according stats and do simple survey about screwdrivers.
I’m going to be honest, I think that this is a case where companies will always dodge the rules unless the consequences are so severe they’re unwilling to risk it. Something like forced downsizing, or a fine proportional to annual revenue. That would make companies significantly more hesitant to try and tread the line.