March Regulatory Update
EU: European Commission Guidance on EU Batteries Regulation Removability Requirements published
2025-02-19
It is focused on the application of provisions on the removability and replaceability of portable batteries and LMT batteries included in Article 11 of the Regulation (EU) 2023/1542. There is an open process to propose further exemptions ("derogations") until April 30, 2025.
The European Commission (EC) published on January 10, 2025, a guidance on the European Union Batteries Regulation 2023/1542. It is focused on Article 11, and the challenging requirement that portable batteries be ‘readily removable and replaceable by the end user at any time during the lifetime of the product’.
The EU Batteries Regulation requires that products containing batteries be designed to ensure the batteries are removable and replaceable by the end user, unless an exemption applies. There are two very narrow exemptions for:
• Products designed to be operated in an environment that is regularly subject to splashing water, water streams or water immersion (known as the ‘wet environment exemption’).
• Certain limited categories of medical devices must be designed for removability.
These exemptions are “partial” because products that qualify for them must still be designed to allow for battery replacement by an independent professional. There is also a very narrow exemption for certain limited categories of products which require a continuous power supply for safety or data integrity reasons. This is a “full” exemption, that is, products that qualify do not need to have batteries that can be removed and replaced by either end users or independent professionals.
In practice, the exemptions will only apply to a very small number of products. This requirement poses significant technical challenges and potential safety concerns for manufacturers, mainly because the Batteries Regulation specifies that the use of heat or solvents to remove and replace batteries will not be permissible.
Key aspects of the guidance:
No damage
The guidance specifies that, ‘The replaceability of portable … batteries means that the battery can be removed and replaced with another battery without damaging or destroying the battery or the device where it is incorporated’. This additional requirement creates further design complexities, especially for products containing delicate batteries (such as pouch cells) or using one-time fixings.
Tools
The Batteries Regulation requires that removal be possible using ‘commonly available’ and not proprietary tools. To assist with interpreting this term, the guidance refers to standard EN 45554:2020e, which clarifies that ‘proprietary tools’ means tools not available for purchase by the general public, or which cannot be licensed under fair, reasonable and non-discriminatory terms.
Mobile phones and tablets
Mobile phones and tablets subject to disassembly and repair requirements under the Ecodesign Framework (Directive 2009/125/EC) should comply with those requirements, rather than the removability and replaceability requirements under the Batteries Regulation. However, these products must still comply with other requirements under the Batteries Regulation, such as the due diligence policy requirements, labelling obligations and conformity assessment procedures.
Independent professionals
‘Independent professionals’ are defined as independent operators ‘who have the technical competence and qualification to repair the product where the battery is integrated into, and conduct their business on commercial basis and/or in commercial premises’.
‘Parts-pairing’
‘Parts-pairing’ – a practice whereby software is used to identify if appropriate batteries are fitted to a product by use of a unique identifier – will not be permitted. The guidance suggests that this is because parts-pairing can impede repairs. It also suggests that this is a complete ban, which will be disappointing for many manufacturers that had sought recognition in the guidance that the use of software should be permitted to prevent the use of unsafe or incompatible replacement batteries. Software features can be used to notify consumers that a non-original battery is being used, as long as the software features do not affect the device functionality or user experience.
Wet environment exemption
The EC is intending the available exemptions to be interpreted narrowly, giving examples of shavers, hair clippers, epilators and electric toothbrushes as types of products that will fall within the wet environment partial exemption. The guidance notes that manufacturers relying on this exemption will need to ensure that product technical documentation includes ‘evidence’ that designing for removability by an end user would compromise the safety of the user or the product, and that there is no way to redesign the product without ‘severely affecting the health and safety of the end user, or the performance and functionality of the product’. There is no guidance given on what level of detail would be required. The Ingress Protection (IP) rating is specified as not being sufficient in itself to justify the wet environment exemption.
Medical device exemption
Many medical devices will be subject to the removability and replaceability requirements. The situation for medical devices is complex, and companies designing medical devices containing batteries should read the guidance carefully to determine whether their products may be able to benefit from an exemption. Full or partial exemptions may apply to implantable medical devices, and certain medical imaging, radiotherapy and in vitro diagnostic devices.
Continuity of power supply exemption
The EC has taken a narrow approach to the types of products which could benefit from this exemption, giving examples of smoke or gas alarms, carbon monoxide alarms designed for at least 10 years of uninterrupted operation, and ‘batteries whose main function is to power a volatile memory itself or deliver backup functions in the internal clock of a device, such as CMOS (Complementary Metal-Oxide Semiconductor) batteries found in digital cameras, processors, sensors, and medical devices’. Hardware used by the digital payments industry also is mentioned as potentially exempt.
Next steps
• The removability and replaceability requirements apply from February 18, 2027, so manufacturers need to start making design decisions now in order to ensure their products will comply with these new requirements.
• The EC has initiated a process to consider whether there should be any further derogations to the removability and replaceability requirements. Submissions are due by April 30, 2025 (link provided below). The expectation is that the additional derogations will be extremely limited in scope, and that evidential requirements will be very high. In practice, it is likely to be challenging for manufacturers to make the case for an exemption, especially if there are other similar products in the market that have been (re)designed for removability and replaceability of the battery.
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Brazil: INMETRO published Portaria 25/2025 on New Procedures for Granting Registration
2025-03-03
It entered into force on January 17, 2025. It changes criteria and procedures for product registration. It establishes the criteria for the initiation of the administrative process of suspension and cancellation of registration, as well as reinforces deadlines and other conditions of this process.
On January 17, 2025, INMETRO/CONMETRO published Portaria No. 57 to amend Portaria No. 258 on Procedures for Granting Registration and for Charging the Fee for Products Subject to Mandatory Conformity Assessment.
This Portaria modifies the criteria and procedures for registering products requiring mandatory conformity assessment. It updates Portaria No. 258/2020, establishing new rules for suspending and canceling registrations while reinforcing deadlines and compliance conditions.
The main changes and provisions are:
1. Suspension of Registration can occur if:
• The product poses risks to safety, health, or the environment.
• The product lacks clear and accurate labeling or information.
• It fails to meet regulatory requirements or loses its conformity certificate.
• There are irregularities in the registration process.
2. Cancellation of Registration will be applied when:
• The product has irreversible safety issues.
• The manufacturer continues production or sales during the suspension.
• Fraud or false documentation is detected.
• The product is banned from the national market.
3. Enforcement and Penalties:
• Inmetro may prohibit sales and require product recalls.
• Non-compliance may lead to sanctions under Law No. 9.933/1999.
• Affected companies can present a defense and appeal within 10 days.
• Public warnings will be issued if a product poses health or safety risks.
Chile: New Protocol published for Saws (Safety Certification)
ENEC Scheme - New Version for OD ECS 040-1 Summary of Testing
Peru: New Technical Standards on Electronic Equipment, EV Batteries and Others approved
Thainland: Several Industrial Standards released
Malaysia: Energy Efficiency and Conservation Act (EECA) 2024 - Guidelines on Energy-Using Product published
2025-03-04
The Guidelines for the implementation of EECA came into operation on January 1, 2025. For the new energy using products intended to be sold in Malaysia, manufacturers and importers shall obtain a Certificate of Efficiency (COE).
The Suruhanjaya Tenaga (ST, Energy Commission) published on December 30, 2024, the Guidelines on Energy-Using Product GP/ST/No.50/2024. They are to specify the detail requirement on:
(a) the energy-using product;
(b) the energy efficiency criteria, testing methodology;
(c) the minimum energy performance standards;
(d) the energy efficiency rating table and calculation method for each of energy products;
(e) the methodology of calculation of the energy efficiency rating; and
(f) the Energy Efficiency Labeling requirement and specification.
(b) the energy efficiency criteria, testing methodology;
(c) the minimum energy performance standards;
(d) the energy efficiency rating table and calculation method for each of energy products;
(e) the methodology of calculation of the energy efficiency rating; and
(f) the Energy Efficiency Labeling requirement and specification.
There is a new process of Energy Efficiency requirement in Malaysia according to the Energy Efficiency and Conservation Act (EECA) 2024, which came into effect on Jan 1, 2025. Under this Act, for the new energy using products intended to be sold in the Malaysian market, manufacturers and importers shall obtain a Certificate of Efficiency (COE).
The products below are regulated as Energy-Using Products under EECA:
• Television;
• Domestic Fan;
• Refrigerator;
• Lamp;
• Air-Conditioner;
• Washer;
• Rice Cooker;
• Microwave Oven;
• Freezer; and
• Electric Oven.
• Domestic Fan;
• Refrigerator;
• Lamp;
• Air-Conditioner;
• Washer;
• Rice Cooker;
• Microwave Oven;
• Freezer; and
• Electric Oven.
The scope of regulated products under EECA includes domestic, commercial, and industrial products, as specified in the attachment.
Starting from February 24, 2025, ST has developed temporary measures to cater for COE application. There is no separate application required for COE. Applicants may apply for a COE by applying for a Certificate of Approval (COA) through the ePermit system. Applicants shall follow the procedures detailed in the Guideline for the Approval of Electrical Equipment 2024 and submit the document as listed in the Guideline for the Approval of Electrical Equipment 2024 (From Page 43 onwards).
Montenegro: Energy Efficiency Labelling of Air Conditioners, Pravilnik No. 112/2025
Recognition of the energy efficiency accreditation in Brazil (INMETRO) for the regulations in Honduras renewed
USA: Implementation of Energy Efficiency Rules on household appliances postponed
Brazil: ANATEL Act 2105/2025 on IoT technologies published
2025-02-26
It entered into force on February 14, 2025, and its application will be mandatory as of August 13, 2025. It updates the technical requirements for Mobile Phones and Terminal Access Stations (ETA).
It was published on February 14, 2025. Now it allows some IoT technologies as 5G NB-NTN, 5G RedCap , and 4G LTE Cat 1bis.
Brazil: ANATEL published and approved the Frequency Band Allocation and Distribution Plan
EU: Harmonised Standards for Radio Equipment under Directive 2014/53/EU amended
Indonesia: Amendment Published - Use of Radio Frequency Spectrum Based on Class Permits
Indonesia: Regulation on Foreign Test lab recognition published
Mexico: Agreement approving Technical Provision IFT 016-2024 on Specifications for Generic Low Power Radio Equipment (DRBP) published
Mexico: Agreement approving Technical Provision IFT-017-2023 for Radio Equipment using Digital Modulation Techniques published
Saudi Arabia: Frequency Spectrum Regulations for Radio Services and Applications published
#2095 Product Certification Checklist - Version 17 published
2025-02-20
A new version for the checklist has been published and shall be used for all new projects.
A new version for the checklist has been published and shall be used for all new projects.
You can download the WORD file from AM-System by clicking on below link.
All changes in comparison to the previous version are highlighted in the tracking version – also available via the link.
The checklist is used for projects leading to CB, DEKRA Mark, KEMA-KEUR, HAR, ENEC, ENEC+, CCA/NTR, GCC, GAC – RoHS, EE LATAM, AOC, DTC, IECQ, Oman LV certification.
DEKRA visited the Saudi Standards, Metrology and Quality Organization (SASO) and the Saudi Electricity Company (SEC) to discuss new opportunities for cooperation
IAF Mandatory document for the Use of Information and Communication Technology (ICT) for Conformity Assessment Purposes (IAF MD4:2025 issue 3) published