- Short answer
- Only units already placed on the EU market before 18 February 2027; each later unit with a portable battery needs it user-replaceable unless exempt.
- Distributor stock
- Batteries that distributors placed in stock in the Union before the date need not meet the new requirements (recital 11).
- Importer's or manufacturer's warehouse
- Manufacturer or importer stock not yet made available is not yet placed; release for free circulation generally counts as placing.
- EU fulfilment warehouse
- Placed when released for free circulation.
- Shipping from outside the EU
- Placed when an end user's order for an already-made unit is confirmed and ready to ship.
- What Shopify documents
- No Shopify Help Center page we read on 25 September 2026 describes a stock transition period.
What counts as a unit already on the EU market?
Article 11(1) applies from 18 February 2027 to whoever “places on the market products incorporating portable batteries”. Article 3 defines placing on the market as “the first making available of a battery on the Union market”.
The Commission's Blue Guide says this “refers to each individual product, not to a type of product”:
individual units of the same model or type, which are placed on the market after the new requirements have become applicable, must comply with these new requirements.
Exemptions from the duty are in our user-replaceable battery answer.
Does it matter whether a reseller or you hold the stock?
Compliant products, once placed, “may subsequently be made available along the delivery chain without additional considerations”, the Blue Guide says, “unless otherwise specified in the legislation”. The Regulation's recital 11 covers distributors' stock:
batteries placed in stock in the Union by distributors, including retailers, wholesalers and sales divisions of manufacturers, before the date of application of relevant requirements of this Regulation do not need to meet those requirements.
Stock you hold as manufacturer or importer and have not yet supplied is not yet placed: placing “is considered not to take place” while a product sits “in the stocks of the manufacturer … or the importer”, per the Blue Guide. Elsewhere, though, the guide generally treats release for free circulation as placing.
Under Article 44, an importer or distributor using its “own name or trademark” is the manufacturer; see our role table.
When does a Shopify order place a unit on the EU market?
The Blue Guide ties it to your supply chain:
- Already on the EU market: placed earlier by the manufacturer or importer.
- EU fulfilment warehouse: placed when “released for free circulation”.
- Shipped from outside the EU: placed once an end user's order is “confirmed for a specific product already manufactured” and ready to ship.
In the Commission's Article 11 guidelines, C(2026) 5032, the only passage we found on units placed pre-deadline says their spare-parts duty “is not applicable”.
No Shopify Help Center page we read on 25 September 2026 (consumer protection, Managed Markets prohibited items, GPSR) describes a battery stock transition period.
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