Euralarm calls for pragmatic implementation of EU Battery Regulation

Euralarm has published a new position paper addressing key implementation challenges related to Regulation (EU) 2023/1542, with a particular focus on Article 11 requirements for battery removability and replaceability.

The paper highlights the need for a balanced and practical approach that safeguards safety, performance, and design integrity - especially in critical safety systems such as fire detection and alarm devices.

Ensuring safety and feasibility

While the Regulation aims to enhance sustainability by requiring portable batteries to be removable and replaceable by end-users, Euralarm underlines that this principle cannot be universally applied without compromising safety or functionality.

The position paper notes that the Regulation itself already recognises this through exemption possibilities, for example in long-life smoke alarms where permanent battery connections are essential to ensure continuous operation and user safety.

Call to reopen exemption procedure

Euralarm is urging the European Commission to reopen the procedure foreseen in the 2025 Commission Notice to allow stakeholders to submit new requests for exemptions under Article 11(4). The association stresses that such a procedure should:

Be launched in the first half of 2026
Be repeated regularly (at least annually)
Allow exemptions to be assessed before requirements become applicable

This would prevent unnecessary product redesigns and avoid imposing obligations that may later be lifted.

Addressing legal uncertainty

The position paper also raises concerns about the current lack of clarity surrounding pending derogation requests. Following the Commission’s 2025 call, 81 applications were submitted, but decisions are still ongoing. This situation creates uncertainty for manufacturers whose products may or may not qualify for exemptions.

Euralarm therefore calls for:

An extension of the compliance deadline under Article 11
A minimum two-year transition period for manufacturers if exemptions are rejected

Such measures would ensure proportionality and allow companies sufficient time to adapt production processes, supply chains, and product designs.

Supporting a balanced regulatory framework

Euralarm emphasises that its proposal is fully aligned with the objectives of the Battery Regulation - reducing environmental impact while ensuring safety and technical feasibility. By enabling a more flexible and timely exemption process, policymakers can ensure that sustainability goals are met without unintended consequences for safety-critical equipment or the wider market.