Apple Watch exempt from EU battery replacement requirement

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From February 2027, batteries in devices sold in the EU must generally be user-replaceable. The EU Commission has now exempted smartwatches from this rule – but not as comprehensively as it initially sounds.

On July 14, the European Commission adopted a delegated act exempting six further product categories from the requirements regarding the removable and replaceable batteries of devices. These include wearables such as smartwatches and fitness trackers – and thus also the Apple Watch. Which Apple products were subject to the rule and which were not was previously a matter of interpretation; for the Apple Watch, this question has now been resolved.

Six new categories on the exception list

In addition to wearables, electrical toys and devices within the scope of the ATEX Directive are on the expanded list – that is, equipment for potentially explosive atmospheres such as sensors, pumps, or forklifts. The Commission justifies this by stating that access by end users could compromise the safety, durability, or water resistance of these products. Some devices are simply too small for safe battery changes or require compact, sealed housings.

Until now, the list mainly included medical devices and so-called wet devices – such as electric toothbrushes or oral irrigators – that regularly come into contact with splashing or jet water.

The exception is not an exemption

It's worth taking a close look at the battery regulations here, because the exemption doesn't mean the battery is untouchable. Article 11, paragraph 1 requires that device batteries can be easily removed and replaced by the end user – this requirement comes into effect on February 18, 2027. Paragraph 2 allows listed products to be designed so that the battery can only be replaced by independent experts. Wearables fall precisely under this paragraph.

The interchangeability doesn't disappear, it just shifts: from the kitchen table to the workshop. And the accompanying obligations remain. Replacement batteries must be available at a reasonable and non-discriminatory price for at least five years after the last unit of a model has been sold – for both specialist workshops and end users. Software must not make it difficult to replace the battery with a compatible one.

For Apple, this means the sealed case of the Apple Watch can remain; a redesign for the EU market is unnecessary. The company isn't off the hook, however.

How the easing of restrictions came about

The timing has a backstory. According to a Politico report, the relaxation of the rules came about after US representatives criticized European battery regulations – specifically concerning Meta's new smart glasses, whose market launch in Europe depended on these regulations. A Commission spokesperson rejected the accusation that they had caved to pressure: The proposal was the result of broad public consultation with consumer groups, industry, and member states, and it did not target a single product, but rather cases where opening a device poses safety risks or is technically unrealistic.

Both points are verifiable: In 2025, the Commission did indeed launch an application process for additional exemptions and commissioned external experts to review the application. It is equally verifiable that the criticism from Washington preceded the decision.

The step is not yet final

The legal act now goes to the European Parliament and the Council of the EU. If neither objects, it will enter into force 20 days after its publication in the Official Journal. An objection is possible, but this is the exception for delegated acts.

One detail the Commission itself addresses: Small lithium-ion batteries that are improperly disposed of are increasingly causing fires in waste treatment plants. Any exception to the removal requirement exacerbates this problem – a point that is likely to be considered in future applications.

The exception does not apply to the Apple Pencil

How narrowly defined the list is becomes clear when looking at another Apple accessory. The exception doesn't apply to the Apple Pencil, which is why Apple is reportedly working on a new version with a replaceable battery. The regulation thus continues to force Apple to make modifications – just not to the watch.

What this means for buyers in this country

In Germany and Austria, the usual procedure remains unchanged: Apple Watch battery replacements will continue to be handled by Apple and authorized service partners, and from 2027 onwards, independent specialist companies will also be required to offer this service. Switzerland is not subject to the battery regulations anyway – it is not an EU member, and the regulations only apply to products placed on the EU market.

The real win is on Apple's side: An Apple Watch that would have had to be redesigned for Europe would have been a different watch – thicker, with visible screws, possibly with a weaker seal. This version will now not be released. (Image: Shutterstock / Wongsakorn 2468)