Your Next Smartwatch May Keep Its Glued Battery: Inside the EU's Wearable Carve-Out

One of the most consequential design rules in consumer electronics cleared its last procedural hurdle this week, and it will shape how your next smartwatch is built. The European Commission's delegated act widening the list of products that may skip end-user battery replacement, adopted on 14 July 2026, reached the end of its European Parliament and Council scrutiny period on 14 October, according to the procedure timeline published on EUR-Lex. Barring an objection, the act enters into force 20 days after its publication in the Official Journal, sealing the carve-outs that decide whether your wearable ever gets a user-swappable battery.

The stakes trace back to Article 11 of the EU Batteries Regulation (Regulation (EU) 2023/1542), which takes effect on 18 February 2027, barely four months from now. The general rule is blunt: portable batteries built into products must be readily removable and replaceable by the end user, for the whole of the product's lifetime. And "readily" has real teeth. As law firm Hogan Lovells explains in a fresh analysis, a battery counts as readily removable only if it can be taken out with commercially available tools, without specialised tools (unless supplied free with the product), proprietary tools, heat, or solvents.

That standard threatened to force redesigns across wearables, hearables, and compact sealed gadgets, where glued-in batteries and tight enclosures are the norm. After a stakeholder consultation launched in February 2025 that drew 81 applications, the Commission's July delegated act, C(2026) 5031 final, broadened the list of products whose batteries need only be replaceable by independent professionals, rather than consumers themselves.

The carve-out list, in detail

The revised derogations now cover eight categories: wet-environment appliances, including certain wearables designed to operate around water; professional medical devices such as imaging, radiotherapy and in-vitro diagnostic equipment; certain wearable devices where consumer battery access could compromise safety, durability or water resistance, either because they are too small for safe battery replacement or rely on a compact sealed enclosure; electric toys, on a temporary derogation running to 31 July 2030 where necessary for safety; wireless thermometer probes designed for food contact; explosion-proof equipment under the ATEX Directive (2014/34/EU); on-body systems for the subcutaneous administration of medicinal products; and roof-mounted telematics devices for agricultural and construction machinery built for vibration, dust and wet conditions.

The critical point, stressed in both the legal analysis and a compliance breakdown published by Kingwo IoT this week, is that these are not blanket exemptions. Most apply only where letting the end user reach the battery would compromise the safety of the user or the product. Being a wearable is not enough on its own. Having an IP rating is not enough on its own. Manufacturers must assess each product design against the actual criteria and be prepared to show their working, including evidence that consumer access would genuinely compromise safety, durability or water resistance.

What "professional replacement" really guarantees

A derogation does not authorise sealed-for-life batteries. The battery must still be removable and replaceable by independent professionals, using commercially available tools, and the tools for the job must be available to independent repair shops at non-discriminatory pricing. The Commission's companion guidance, C(2026) 5032 final, defines independent professionals as operators with the technical competence and qualifications to repair the relevant product, working on a commercial basis.

The backup guarantee is in Article 11(7): portable and light-means-of-transport batteries must remain available as spare parts for at least five years after the last unit of a model is placed on the market, at reasonable and non-discriminatory prices. A professional-replacement derogation therefore does not remove the need to plan for battery servicing; it converts it into a statutory servicing obligation.

This is the part of the story that matters most for the repair world. Independent repair shops get guaranteed access to batteries and the means to fit them, a statutory footing in product categories where sealed designs previously left them shut out. The guidance even settles two edge cases that had been causing headaches: charging cases and power banks fall entirely outside Article 11, because they effectively are portable batteries rather than products incorporating one; and the wet-appliance derogation is confirmed to cover wireless earbuds, heart-rate straps, smart glasses and watches that genuinely meet the criteria, potentially saving many products from redesign.

The EU is not asking manufacturers to choose between waterproofing and repairability. It is asking them to guarantee that someone qualified can get inside, with standard tools, five years from now.

Your next smartwatch, still sealed

For consumers, the headline is deflationary. The next generation of smartwatches will probably not arrive with user-swappable batteries, a verdict that tech outlets including Android Authority drew within days of the July adoption. Smartphones are not among the exempted categories, so phones remain subject to the general rule, with batteries replaceable using common tools or manufacturer-provided ones. Wearables were always the headline exemption.

Yet the market is not standing still. Google's Pixel Watch 4 launched as the company's first genuinely repairable smartwatch, and iFixit gave the Pixel Watch 5 a 9 out of 10 for repairability, noting the display comes off with two Torx screws and a gasket, with no adhesive at all. Apple remains the mirror image: iFixit scored the Apple Watch Series 12 at 4 out of 10 this month, citing a glued display and battery access that requires going through the screen, and gave the Watch Ultra 4 the same 4 out of 10 it has handed every Ultra model. The regulation will not force these approaches to converge. But the professional-replacement floor means even the most sealed design must still yield to a trained technician with standard tools.

What happens between now and February 2027

The delegated act's three-month objection window, extendable by two months at Parliament's or the Council's initiative, is listed by EUR-Lex as ending on 14 October 2026. Assuming no objection, publication in the Official Journal follows, and entry into force arrives twenty days later. That puts the exemptions on firm legal ground roughly four months before Article 11 itself bites.

Manufacturers now face a compliance sprint with clearer rules but no room for assumption. The new framework rewards those who treat each product individually: a tracker's connectivity, compact size or waterproof housing does not prove eligibility, and an assumption that sealed hardware is exempt is exactly what the guidance warns against. For repair businesses, the message runs the other way: the right to service these products professionally is now anchored in EU law, backed by spare-part availability and non-discriminatory pricing. The fight over who gets to open your gadgets did not end in Brussels this week. It just moved from whether the battery can be reached to who is allowed to reach it.