> > The obligations laid down in paragraph 1 shall not apply where continuity of power supply is necessary and a permanent connection between the product and th

> > The obligations laid down in paragraph 1 shall not apply where continuity of power supply is necessary and a permanent connection between the product and the respective portable battery is required to ensure the safety of the user and the appliance or, for products that collect and supply data as their main function, for data integrity reasons. > Another potential loophole? Safety of user is not a concern for cell phone. Because it is possible to make a cell phone where a battery can be swapped a "safety of the appliance" would not apply. The "collect and supply data as their main function" is intended as a carve out for devices like credit card readers, some of which have anti-tamper circuits will wipe critical data from the device if opened. These work by storing the data in SRAM, and using a battery backup for it (so that a power outage or unplugging it won't wipe it). They have contacts that detect if the case is opened, and that trigger wiping the data. This was especially important for older mag-stripe readers where one could hypothetically install a skimmer inside the main reader if it continued to work after opening it. Hence, while they can often be disassembled with just commercially available tools, a normal user replacing the battery is not possible, as the factory needs to reprogram it afterwards, and they will insist on inspecting the unit for tampering before they do so. Requiring reprogramming by the manufacturer after battery replacement does not qualify as a replaceable battery under this regulation, so these devices need a carveout.