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Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries Article 11 Removability and r

by rendx 10mo ago

Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries Article 11 Removability and replaceability of portable batteries and LMT batteries 1. Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product. That obligation shall only apply to entire batteries and not to individual cells or other parts included in such batteries. A portable battery shall be considered readily removable by the end-user where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product. Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those products are accompanied with instructions and safety information on the use, removal and replacement of the batteries. Those instructions and that safety information shall be made available permanently online, on a publicly available website, in an easily understandable way for end-users. […] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02023R1542-20250731 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A... (This is active law; there is however a grace period for products until 2027.)

dmitrygr 10mo ago
Good thing that there are plenty of markets outside of EU
- bigiain 10mo ago
  Cynical thinking ahead. What has been long considered one of the most wealthy markets is a country descending into a billionaire controlled kleptocracy. And they're pissing off every other country in the world with tariff blackmail and punishment (or extra judicial executions) for any country that fails to bend the knee and fawn obsequiously enough to their leader. One of the most populous markets is a country that manufactures approximately 100% of all consumer electronics, and will have a hundred versions of this available for 10% of Pebble's price on AliExpress as soon as it shows any signs of gaining market traction anywhere (quite likely stolen or "3rd shift" ones from Pebble's own outsourced production line). India, who these days has more than enough local skill and experienced ex-H1B tech people to create this from scratch at home (and at least some with a deep resentment over how they were treated by US tech companies while they were there)? One of the no longer EU markets is suffering post Brexit austerity and isn't likely to be buying a heap if tech toys - even if their fucked up new importing goods paperwork doesn't make it impossible to get your product into the country. There goes about 40% of the planet's population. That leaves, what? Manufacture locally and try surviving by selling to the US market at prices driven by US labor costs which'd make the product prohibitively expensive globally? South East Asia, who're likely to buy the Samsung copy over one from a US company? Russia, who (at least for now) is under trade sanctions for a US based company like Pebble? So perhaps Canada (until their southern neighbour make good on their threat to try and make them the 51st state)? South Africa? Australia and New Zealand?
  - deleted 10mo ago
    [deleted]
  - jabbywocker 10mo ago
    You’re 100% correct companies can’t survive by being a niche market choice. The options are complete global market saturation or failure. /unjerk out of all the potential mindsets to inherit from the US, the “corporate maximalist” frame of reference is one of the dumbest we have to offer
bradleybuda 10mo ago
Wow, sucks to bE yoU!
- 47282847 10mo ago
  As a European, I actually fully support this regulation!
  - ddoeth 10mo ago
    Me too, i hate that I would have to throw out a fully functioning device if the battery dies.
    - jeremyjh 10mo ago
      I understand that sentiment but I think its arbitrary. People buy lots of products that don't have a useful life exceeding two years. For example, every pet toy ever sold. Some will have higher impact for manufacturing and disposal than this ring.
      - deleted 10mo ago
        [deleted]
      - 47282847 10mo ago
        1. Arbitrary it may be. You have to start somewhere. In that sense, anything we do is “arbitrary“. Straw man. (see also: ban of plastic straws) 2. I would expect pet toys to be regulated as well and to contain less environmental toxins and hard to recycle elements than batteries, so I doubt the claim about impact per item sold.
        jeremyjh 10mo ago
        There is an endless stream of cheap battery powered pet toys flowing out of China with far more plastic, circuit boards etc than this watch.
kstrauser 10mo ago
While I sympathize with the intent of the law, this is a great example of why it's dumb. There's no possible way you could make that ring, in a reasonably ring-sized form factor, with today's manufacturing processes in such a way that an end user could replace it.
- lemming 10mo ago
  If this law pushes back against the idea that it's ok to make endless tech products which are essentially future rubbish as soon as you buy them, then I think that's a good thing. Perhaps products like this just shouldn't exist until we have better ways of dealing with the remains.
  - GolfPopper 10mo ago
    Yep. There's some strong "How dare they interfere with Thneed production!" energy.
  - kstrauser 10mo ago
    The problem is that it makes it impossible to have a version 0 to iterate on until a whole lot of other industries have advanced. Imagine the situation of in-ear hearing aids: they shouldn't be allowed to exist until they're perfect, unless we're happy telling deaf people they have to wear much larger than necessary devices and advertise their disability. I'm glad we're reducing e-waste. I'm not thrilled about the idea of saying you can't make a thing until 100% of the bugs are worked out, meaning you can't have a beta version for research and fundraising, meaning, you can't conjure the perfect version into existence.
    - wing-_-nuts 10mo ago
      That's hyperbole and I think you know it. I'm pretty sure they explicitly exclude medical devices.
      - kstrauser 10mo ago
        It's not hyperbole at all. Fortunately, your link basically says it doesn't apply to something you wear on your hands or arms: > By way of derogation from paragraph 1, the following products incorporating portable batteries may be designed in such a way as to make the battery removable and replaceable only by independent professionals: > (a) appliances specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion, and that are intended to be washable or rinseable; But the only mention of "medical" comes right after it, and doesn't include hearing aids, future smart glasses, etc.: > (b) professional medical imaging and radiotherapy devices, as defined in Article 2, point (1), of Regulation (EU) 2017/745, and in vitro diagnostic medical devices, as defined in Article 2, point (2), of Regulation (EU) 2017/746. So ironically, the law allows disposable "junk devices" people are complaining about here, but doesn't allow factory-only serviceable hearing aids. How 'bout that? We can buy our smart rings and throw them away, but hearing aids will have to remain giant hunks of heavy plastic, or at least the models purchasable by average people who can't fly out of the EU to buy the good ones. Edit: It's easy to downvote. I cited the relevant law. If I'm wrong, cite other law that explains why.
tacker2000 10mo ago
Its going to be interesting to see what will happen with Airpods and the like…
- fsh 10mo ago
  Apple will proudly announce that they've invented the replaceable battery.
  - Cthulhu_ 10mo ago
    Unapologetically plastic. or replaceable. Their marketing department will work hard to sell it as revolutionary.
- nixonpjoshua 10mo ago
  I don't think it will be possible to make wireless earbuds or a ring with replaceable batteries without seriously compromising the ergonomics of fitting onto or into the human body. I have a pair of earbuds designed to be as diminutive for sleeping comfortably and I have no idea how you would do that with a replaceable battery even if Airpod sized devices can be done.
  - numpad0 10mo ago
    Counterexample: hearing aids.
    - kllrnohj 10mo ago
      Now use rechargeable batteries that are not user replaceable
  - realusername 10mo ago
    The Fairbuds proved that it's possible.
  - FrinkleFrankle 10mo ago
    What are those sleeping earbuds?
pedalpete 10mo ago
We regularly get contacted by people in Europe who want to buy our product, but we haven't been providing support due to the cost of certs, and other regulatory needs (medical/wellness device). We want to help people in the EU, but with laws like replaceable batteries, it's going to push us further and further away from being able to do that. Our product is designed to be refurbished, but not user-replaceable. At the same time, how many products do people give up on because of battery life, and is this a non-issue with future battery chemistries? Do people replace their phones because the battery isn't good anymore, or is it more likely they've broken the screen, cameras, etc to the point where it doesn't make sense to replace those anymore? Or they just want the newest thing?
- lawn 10mo ago
  I guess Core use the same excuse to only provide 30 day warranty, using a loophole to avoid the annoyance of having to provide a proper warranty?
- maest 10mo ago
  > Our product is designed to be refurbished, but not user-replaceable. Why?
  - Tempest1981 10mo ago
    Design inherently involves trade-offs. Size, weight, cost, water resistance, etc.
  - bigiain 10mo ago
    I'm not who you asked that question, but I'd guess it's because it requires "proprietary tools, thermal energy, or solvents to disassemble the product." It'd be hard to design/manufacture a device that reliably remains waterproof after a typical not-specially-skilled owner opens it up to replace a battery. It's really common to hear of people damaging watches due to water ingress after battery replacements, getting seals or orings seated just right isn't something every user is going to be able to do. I can imagine some medical devices have similar sealing requirements, perhaps even more robust sealing methods since they might need to be exposed to regular disinfection grade cleaning with chemicals harsher then just water. I could easily understand why a company may design a medical device that its heat-glued together for sealing purposes in a way that can only reasonably be done (and redone) at the factory. I killed an original Pebble when I Dremelled it open to replace the battery, and failed to hot glue seal it well enough and it got wet inside. Having said that - I dislike this design choice for the Index 01. I can see myself becoming reliant on this right before they sell out to Garmin or whoever and tell all their customers to FOAD again. Trust is very hard to win back.
munchler 10mo ago
There's an exception for "appliances specifically designed to operate primarily 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 ring is described as water-resistant, so I wonder if it would be allowed?
- rbits 10mo ago
  I don't know if it counts as "primarily" operating in those conditions.
  - scratchyone 10mo ago
    From my reading, the conditions seem to apply to the environment it primarily operates in, not the product itself. So the product primarily operates in the environment of the hand, and the hand is definitely "regularly subject to splashing water".
    - dangus 10mo ago
      I hate to say it, but none of this matters. This product is going to fail anyway. It’s a niche within a niche within a niche. It’s designed to do solve a problem that only one person has. You have to: - want to make voice memos (how many people do that?) - find your watch insufficient for that purpose - find your phone insufficient for that purpose - be willing to wear a ring on a specific finger (this isn’t practical on most of your fingers because it’s hard to press the button) - commit to custom sized jewelry
      - embedding-shape 10mo ago
        I hate to be the person to break it to you, but you're in the wrong subthread and none of what you wrote matters, the context is specifically about the regulation. There is a bunch of other subthreads where people moan about that this doesn't have any actual market.
afandian 10mo ago
> at any time during the lifetime of the product Eric said that the lifetime of the product is 'up to years'. Presumably because that's the limitation imposed by a disposable battery. I wonder if the circular reasoning would fly in the EU.
apparent 10mo ago
How do other smart-ring companies deal with this?
- deleted 10mo ago
  [deleted]
- mcpeepants 10mo ago
  wireless charging at the expense of size/bulk
  - apparent 10mo ago
    But the rechargeable batteries are still not user replaceable, right?
clnhlzmn 10mo ago
This makes me wonder about things like air pods. Do they replaceable batteries? Does Apple plan to make them so?
ddoeth 10mo ago
My main concern here is that i live in an area that regularly get's below -20° and my electronic devices are regularly dying around me. And while I try to keep my hands warm-ish, they do get cold sometimes, and it would suck if a non replaceable battery died on me early because of this.
estimator7292 10mo ago
For something like a smart ring, a user-replacable battery is just totally impractical. Particularly if you want any sort of water resistance. The thing is just too damn small and will require special tools no matter what. I don't think it's at all reasonable to expect such a product to have a user-replacable battery without doubling the cost. Sure it'd be nice, but the reality is sometimes it just isn't possible to accommodate.
- PaulRobinson 10mo ago
  The regulation is not some bureaucratic nonsense, it exists for a reason. If its existence means the manufacturer has to do more work, and the cost might rise, that is considered worth it. They can lobby to have the regulation changed, and regulations have changed in the past based on industry input, but saying "it's too hard" does not make the product suddenly legal.

by rendx 10mo ago

dmitrygr 10mo ago

Good thing that there are plenty of markets outside of EU

bigiain 10mo ago
Cynical thinking ahead. What has been long considered one of the most wealthy markets is a country descending into a billionaire controlled kleptocracy. And they're pissing off every other country in the world with tariff blackmail and punishment (or extra judicial executions) for any country that fails to bend the knee and fawn obsequiously enough to their leader. One of the most populous markets is a country that manufactures approximately 100% of all consumer electronics, and will have a hundred versions of this available for 10% of Pebble's price on AliExpress as soon as it shows any signs of gaining market traction anywhere (quite likely stolen or "3rd shift" ones from Pebble's own outsourced production line). India, who these days has more than enough local skill and experienced ex-H1B tech people to create this from scratch at home (and at least some with a deep resentment over how they were treated by US tech companies while they were there)? One of the no longer EU markets is suffering post Brexit austerity and isn't likely to be buying a heap if tech toys - even if their fucked up new importing goods paperwork doesn't make it impossible to get your product into the country. There goes about 40% of the planet's population. That leaves, what? Manufacture locally and try surviving by selling to the US market at prices driven by US labor costs which'd make the product prohibitively expensive globally? South East Asia, who're likely to buy the Samsung copy over one from a US company? Russia, who (at least for now) is under trade sanctions for a US based company like Pebble? So perhaps Canada (until their southern neighbour make good on their threat to try and make them the 51st state)? South Africa? Australia and New Zealand?
- deleted 10mo ago
  [deleted]
- jabbywocker 10mo ago
  You’re 100% correct companies can’t survive by being a niche market choice. The options are complete global market saturation or failure. /unjerk out of all the potential mindsets to inherit from the US, the “corporate maximalist” frame of reference is one of the dumbest we have to offer

bradleybuda 10mo ago

Wow, sucks to bE yoU!

47282847 10mo ago
As a European, I actually fully support this regulation!
- ddoeth 10mo ago
  Me too, i hate that I would have to throw out a fully functioning device if the battery dies.
  - jeremyjh 10mo ago
    I understand that sentiment but I think its arbitrary. People buy lots of products that don't have a useful life exceeding two years. For example, every pet toy ever sold. Some will have higher impact for manufacturing and disposal than this ring.
    - deleted 10mo ago
      [deleted]
    - 47282847 10mo ago
      1. Arbitrary it may be. You have to start somewhere. In that sense, anything we do is “arbitrary“. Straw man. (see also: ban of plastic straws) 2. I would expect pet toys to be regulated as well and to contain less environmental toxins and hard to recycle elements than batteries, so I doubt the claim about impact per item sold.
      - jeremyjh 10mo ago
        There is an endless stream of cheap battery powered pet toys flowing out of China with far more plastic, circuit boards etc than this watch.

kstrauser 10mo ago

While I sympathize with the intent of the law, this is a great example of why it's dumb. There's no possible way you could make that ring, in a reasonably ring-sized form factor, with today's manufacturing processes in such a way that an end user could replace it.

lemming 10mo ago
If this law pushes back against the idea that it's ok to make endless tech products which are essentially future rubbish as soon as you buy them, then I think that's a good thing. Perhaps products like this just shouldn't exist until we have better ways of dealing with the remains.
- GolfPopper 10mo ago
  Yep. There's some strong "How dare they interfere with Thneed production!" energy.
- kstrauser 10mo ago
  The problem is that it makes it impossible to have a version 0 to iterate on until a whole lot of other industries have advanced. Imagine the situation of in-ear hearing aids: they shouldn't be allowed to exist until they're perfect, unless we're happy telling deaf people they have to wear much larger than necessary devices and advertise their disability. I'm glad we're reducing e-waste. I'm not thrilled about the idea of saying you can't make a thing until 100% of the bugs are worked out, meaning you can't have a beta version for research and fundraising, meaning, you can't conjure the perfect version into existence.
  - wing-_-nuts 10mo ago
    That's hyperbole and I think you know it. I'm pretty sure they explicitly exclude medical devices.
    - kstrauser 10mo ago
      It's not hyperbole at all. Fortunately, your link basically says it doesn't apply to something you wear on your hands or arms: > By way of derogation from paragraph 1, the following products incorporating portable batteries may be designed in such a way as to make the battery removable and replaceable only by independent professionals: > (a) appliances specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion, and that are intended to be washable or rinseable; But the only mention of "medical" comes right after it, and doesn't include hearing aids, future smart glasses, etc.: > (b) professional medical imaging and radiotherapy devices, as defined in Article 2, point (1), of Regulation (EU) 2017/745, and in vitro diagnostic medical devices, as defined in Article 2, point (2), of Regulation (EU) 2017/746. So ironically, the law allows disposable "junk devices" people are complaining about here, but doesn't allow factory-only serviceable hearing aids. How 'bout that? We can buy our smart rings and throw them away, but hearing aids will have to remain giant hunks of heavy plastic, or at least the models purchasable by average people who can't fly out of the EU to buy the good ones. Edit: It's easy to downvote. I cited the relevant law. If I'm wrong, cite other law that explains why.

tacker2000 10mo ago

Its going to be interesting to see what will happen with Airpods and the like…

fsh 10mo ago
Apple will proudly announce that they've invented the replaceable battery.
- Cthulhu_ 10mo ago
  Unapologetically plastic. or replaceable. Their marketing department will work hard to sell it as revolutionary.
nixonpjoshua 10mo ago
I don't think it will be possible to make wireless earbuds or a ring with replaceable batteries without seriously compromising the ergonomics of fitting onto or into the human body. I have a pair of earbuds designed to be as diminutive for sleeping comfortably and I have no idea how you would do that with a replaceable battery even if Airpod sized devices can be done.
- numpad0 10mo ago
  Counterexample: hearing aids.
  - kllrnohj 10mo ago
    Now use rechargeable batteries that are not user replaceable
- realusername 10mo ago
  The Fairbuds proved that it's possible.
- FrinkleFrankle 10mo ago
  What are those sleeping earbuds?

pedalpete 10mo ago

We regularly get contacted by people in Europe who want to buy our product, but we haven't been providing support due to the cost of certs, and other regulatory needs (medical/wellness device). We want to help people in the EU, but with laws like replaceable batteries, it's going to push us further and further away from being able to do that. Our product is designed to be refurbished, but not user-replaceable. At the same time, how many products do people give up on because of battery life, and is this a non-issue with future battery chemistries? Do people replace their phones because the battery isn't good anymore, or is it more likely they've broken the screen, cameras, etc to the point where it doesn't make sense to replace those anymore? Or they just want the newest thing?

lawn 10mo ago
I guess Core use the same excuse to only provide 30 day warranty, using a loophole to avoid the annoyance of having to provide a proper warranty?
maest 10mo ago
> Our product is designed to be refurbished, but not user-replaceable. Why?
- Tempest1981 10mo ago
  Design inherently involves trade-offs. Size, weight, cost, water resistance, etc.
- bigiain 10mo ago
  I'm not who you asked that question, but I'd guess it's because it requires "proprietary tools, thermal energy, or solvents to disassemble the product." It'd be hard to design/manufacture a device that reliably remains waterproof after a typical not-specially-skilled owner opens it up to replace a battery. It's really common to hear of people damaging watches due to water ingress after battery replacements, getting seals or orings seated just right isn't something every user is going to be able to do. I can imagine some medical devices have similar sealing requirements, perhaps even more robust sealing methods since they might need to be exposed to regular disinfection grade cleaning with chemicals harsher then just water. I could easily understand why a company may design a medical device that its heat-glued together for sealing purposes in a way that can only reasonably be done (and redone) at the factory. I killed an original Pebble when I Dremelled it open to replace the battery, and failed to hot glue seal it well enough and it got wet inside. Having said that - I dislike this design choice for the Index 01. I can see myself becoming reliant on this right before they sell out to Garmin or whoever and tell all their customers to FOAD again. Trust is very hard to win back.

munchler 10mo ago

There's an exception for "appliances specifically designed to operate primarily 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 ring is described as water-resistant, so I wonder if it would be allowed?

rbits 10mo ago
I don't know if it counts as "primarily" operating in those conditions.
- scratchyone 10mo ago
  From my reading, the conditions seem to apply to the environment it primarily operates in, not the product itself. So the product primarily operates in the environment of the hand, and the hand is definitely "regularly subject to splashing water".
  - dangus 10mo ago
    I hate to say it, but none of this matters. This product is going to fail anyway. It’s a niche within a niche within a niche. It’s designed to do solve a problem that only one person has. You have to: - want to make voice memos (how many people do that?) - find your watch insufficient for that purpose - find your phone insufficient for that purpose - be willing to wear a ring on a specific finger (this isn’t practical on most of your fingers because it’s hard to press the button) - commit to custom sized jewelry
    - embedding-shape 10mo ago
      I hate to be the person to break it to you, but you're in the wrong subthread and none of what you wrote matters, the context is specifically about the regulation. There is a bunch of other subthreads where people moan about that this doesn't have any actual market.

afandian 10mo ago

> at any time during the lifetime of the product Eric said that the lifetime of the product is 'up to years'. Presumably because that's the limitation imposed by a disposable battery. I wonder if the circular reasoning would fly in the EU.

apparent 10mo ago

How do other smart-ring companies deal with this?

deleted 10mo ago
[deleted]
mcpeepants 10mo ago
wireless charging at the expense of size/bulk
- apparent 10mo ago
  But the rechargeable batteries are still not user replaceable, right?

clnhlzmn 10mo ago

This makes me wonder about things like air pods. Do they replaceable batteries? Does Apple plan to make them so?

ddoeth 10mo ago

My main concern here is that i live in an area that regularly get's below -20° and my electronic devices are regularly dying around me. And while I try to keep my hands warm-ish, they do get cold sometimes, and it would suck if a non replaceable battery died on me early because of this.

estimator7292 10mo ago

For something like a smart ring, a user-replacable battery is just totally impractical. Particularly if you want any sort of water resistance. The thing is just too damn small and will require special tools no matter what. I don't think it's at all reasonable to expect such a product to have a user-replacable battery without doubling the cost. Sure it'd be nice, but the reality is sometimes it just isn't possible to accommodate.

PaulRobinson 10mo ago
The regulation is not some bureaucratic nonsense, it exists for a reason. If its existence means the manufacturer has to do more work, and the cost might rise, that is considered worth it. They can lobby to have the regulation changed, and regulations have changed in the past based on industry input, but saying "it's too hard" does not make the product suddenly legal.