Do products you sell on Shopify in the EU need user-replaceable batteries from 18 February 2027?

What counts as a readily removable battery?

From 18 February 2027, Article 11(1) will bind “any natural or legal person that places on the market products incorporating portable batteries”: they will have to be “readily removable and replaceable by the end-user at any time during the lifetime of the product”, as whole batteries rather than individual cells.

Your supply-chain role is mapped in the role table of our battery QR-code answer.

Readily removable means removable with “commercially available tools”: no specialised tools unless supplied free with the product, and no “proprietary tools, thermal energy, or solvents”.

LMT batteries, for light means of transport, and their cells will have to be readily removable and replaceable “by an independent professional” (Article 11(5)).

Which products are exempt, and from what?

• Still removable, by independent professionals only (Article 11(2)): washable appliances designed mainly for splashing water, water streams or immersion, where safety requires it; professional medical imaging and radiotherapy devices, and in vitro diagnostic medical devices.
• No Article 11(1) duty (Article 11(3)): where continuous power and a permanent battery connection are required for user and appliance safety, or for data integrity in products built mainly to collect and supply data.
• Pending: the Commission adopted delegated act C(2026) 5031 on 14 July 2026, adding further exemptions; it is not yet confirmed in force as of 17 September 2026.

The Commission's non-binding guidelines say that, in certain cases where a product's primary function is to deliver electrical energy to other products, such as rechargeable power banks or charging cases for wearables, the product itself can be considered a portable battery, so Article 11 would not apply to it.

What else comes with the duty, and does Shopify cover it?

Two more duties follow: replacement instructions and safety information “made available permanently online”, and batteries available as spare parts for at least five years after the model's last unit is placed on the market.

Battery producer registration is a separate duty, covered in our answer on whether you need to register as a battery producer.

No Shopify Help Center page we read on 17 September 2026, including its consumer protection and GPSR pages, describes the Article 11 removability duty.