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EU Battery Rules Ahead of February 2027: What PCBA Buyers Should Check Now

Two EU battery-related developments in October 2026 deserve attention from companies developing products for the European market.

On 22 October, the Official Journal published Commission Delegated Regulation (EU) 2026/1770. It updates the categories of portable batteries that may be removed and replaced only by an independent professional. The regulation enters into force on 11 November 2026.

A separate development concerns the battery passport. On 19 October, the European Commission opened a consultation on access rights to different parts of the passport data. Feedback is due by 16 November 2026, with adoption of the implementing act planned for the fourth quarter of 2026.

For companies buying PCBA from China, these developments raise two practical questions: does the product design meet the battery removability rules, and can the supply chain provide the records needed to support the battery passport?

The legal responsibilities do not automatically fall on the PCBA manufacturer. However, the information available from the assembly supplier can affect how easily the finished-product manufacturer meets its obligations.

What changed in the EU battery removability rules?

Commission Delegated Regulation (EU) 2026/1770 amends Article 11(2) of Regulation (EU) 2023/1542, the EU Batteries Regulation. It updates the list of product categories that can qualify for an exception to the general requirement for end users to remove and replace portable batteries.

The key dates

14 July 2026 — The Commission adopted the delegated regulation.
22 October 2026 — The regulation was published in the Official Journal.
11 November 2026 — The delegated regulation enters into force.
18 February 2027 — The general battery removability requirement begins to apply.

Product categories with an exception

Product category	Reason for the exception
Appliances exposed to splashing water or immersion, including relevant wearables	Protection against water exposure
Professional medical imaging, radiotherapy and in vitro diagnostic devices	Specifically listed medical-device category
Wearables that are too small for safe user replacement or depend on a sealed enclosure	Safety or water-resistance concerns
Rechargeable electric toys, until 31 July 2030	Size-related safety requirements
Wireless thermometer probes intended for food contact	Removing the battery could compromise the seal and contaminate food
Equipment covered by Directive 2014/34/EU for explosive atmospheres	Requirements associated with potentially explosive environments
On-body systems delivering subcutaneous doses	Battery removal could interrupt dosing
Telematics equipment installed on the roofs of agricultural and construction machinery	Exposure to vibration and dust

These exceptions should not be treated as blanket permission to make any battery permanently inaccessible. Except for the specified professional medical imaging, radiotherapy and in vitro diagnostic category, the relevant conditions and safety justifications still matter.

Product teams should check the actual legal text against their product category and design. The table above is a practical summary, not a substitute for that assessment.

Why PCBA buyers should discuss battery access early

Battery removability may look like a mechanical-design issue, but the decision can affect the electronics as well.

Consider a battery-powered industrial device. If the battery is intended to be replaced by a service professional rather than the end user, the engineering team may need to consider the connector, protection circuit, charging behaviour and service procedure together.

A different product may need to maintain a sealed enclosure to protect against moisture or contamination. In that case, changing the battery arrangement late in development could affect the housing, PCB layout and testing requirements.

The same issue can arise in medical equipment, rugged telematics and products designed for potentially explosive environments. Each has its own operating conditions and regulatory requirements, so the solution cannot be determined from the PCB alone.

For a PCBA buyer, the practical step is to bring the battery requirements into the design review before the mechanical structure and PCB layout are finalised.

Questions worth resolving at that stage

Is the battery intended to be replaceable by the end user or by a professional?
Does the enclosure need to remain sealed during normal service?
Will the battery connection or protection circuit change if the pack is replaced?
Does the firmware need to respond to battery removal, charging restrictions or battery-health information?
Will a design change require a new prototype, test procedure or production approval?

These decisions are easier to handle before tooling and production documentation are locked.

Who is responsible for the battery passport?

The EU battery passport becomes mandatory on 18 February 2027 for the battery categories specified by the regulation, including electric-vehicle batteries, batteries for light means of transport such as e-bikes and e-scooters, stationary battery energy storage systems and relevant industrial batteries placed on the EU market.

According to the European Commission, responsibility for creating and maintaining the passport rests with the economic operator placing the finished battery on the market. A company supplying an individual component or module does not automatically take on that responsibility.

For a PCBA manufacturer, this distinction matters. Kilandu does not create or maintain a customer's battery passport. The assembly supplier's role is to provide accurate manufacturing and component information where agreed and applicable.

Depending on the product and customer requirements, that information may include:

Component traceability — Records connecting incoming components to the production batch in which they were used.
Date codes and lot numbers — Information that helps identify the components fitted to a particular build.
Component sourcing records — Purchasing and verification records that support checks on component authenticity.
Approved substitutions — Documentation showing which alternative components were accepted and when approval was obtained.
Inspection and test records — Results associated with the relevant production batch, where those records are part of the agreed quality requirements.

These records do not, on their own, constitute a battery passport. They can, however, help the responsible company assemble and substantiate the information required for its finished product.

It is worth agreeing on the required data format, retention period and retrieval process before production begins. Reconstructing component history after a shipment has left the factory is much harder than keeping the information with the production records from the outset.

Digital product passport standards: what should suppliers know?

The EU has also published references to six harmonised standards for digital product passports under Commission Implementing Decision (EU) 2026/1736 of 14 July 2026.

The standards cited in the decision

Standard	Scope
EN 18216	Data exchange protocols
EN 18219	Unique identifiers
EN 18220	Data carriers
EN 18221	Data storage and persistence
EN 18222	APIs for lifecycle management and searchability
EN 18223	Interoperability

For a PCBA supplier, these standards are useful context for understanding how digital product information may be exchanged and accessed. They do not mean that every assembly factory must independently operate a battery-passport platform.

The immediate priority is more straightforward: make sure the production information requested by the customer is accurate, consistent and retrievable.

The European Commission's battery-passport framework also uses a QR code to provide access to the passport. The detailed access rights for different categories of information are the subject of the separate implementing-act consultation opened in October 2026.

As those rules are finalised, companies should confirm which data they need to provide, who is authorised to access it and how the information will be maintained throughout the product lifecycle.

Four questions to ask your PCBA supplier before production

A supplier qualification discussion does not need to begin with a complex digital-passport project. Start with the records the factory already maintains and establish whether they meet the needs of your product.

1. Can you trace components to a specific production batch?

Ask whether the supplier can provide component lot numbers and date codes for a named build. Clarify whether the information is recorded during production or would have to be reconstructed later.

2. How are component substitutions approved?

If a component becomes unavailable, the supplier should follow the agreed approval process before fitting an alternative. Confirm how the change, approval and final fitted component are documented.

3. Can you identify the source of the components used?

Ask what purchasing and authenticity-verification records are available. For critical components, establish how the supplier handles suspicious markings, inconsistent date codes or other signs of a potential counterfeit.

4. Which inspection and test records can you retrieve for a particular batch?

Find out whether SPI, AOI, X-ray, ICT or functional-test results are retained where applicable to the product. Confirm whether records can be linked to the relevant batch or serial number and supplied in the format your quality team needs.

These are useful questions even when a product is not subject to a battery-passport requirement. They help establish whether the supplier's quality records can support your own traceability and change-control processes.

Include the agreed requirements in the quality agreement or supply contract. That way, both parties know which information must be retained and what can be requested after shipment.

How Kilandu supports component traceability and quality records

For customers developing BMS boards, energy-storage electronics, medical electronics and industrial-control products, the relevant question is how the factory documents the materials and processes used in each build.

Kilandu's PCBA manufacturing operations in Bao'an, Shenzhen, support projects requiring component sourcing, assembly and quality-control documentation. The exact records available depend on the project scope and the requirements agreed with the customer.

Our quality-control process includes incoming inspection, in-process SPI and AOI, X-ray inspection where required, and electrical or functional testing according to the product and agreed test plan.

For projects involving component substitutions, the approval process should be established before production. This helps ensure that the assembled board remains consistent with the customer's approved BOM and engineering documentation.

Customers who need batch-level traceability should specify the required information at quotation or engineering-review stage. This gives both sides an opportunity to confirm how component records, inspection results and approved changes will be maintained.

Kilandu's published certifications include ISO 9001, ISO 13485, IATF 16949, ISO 14001 and UL-related credentials. Buyers should verify the current validity, scope and applicability of each certificate for the product and manufacturing site concerned.

The battery-passport obligation itself remains with the responsible economic operator. Our role as an assembly supplier is to support the customer's manufacturing and traceability needs through the records and controls agreed for the project.

What should companies do before February 2027?

For a company preparing a battery-powered product for the EU market, there is no need to treat these two developments as a single compliance task. They concern different parts of the product and supply chain.

For the battery removability rules, review the product category and confirm whether an exception applies. If battery access affects the enclosure, connector or PCB design, settle that question before the design is frozen.

For the battery passport, identify the company responsible for creating and maintaining the passport, then map the information it needs to obtain from component and assembly suppliers. Confirm the data format, traceability level, retention period and process for approving substitutions.

Finally, check the supply agreement. If the customer requires batch-level component records or inspection data, define those requirements before the first production run rather than relying on an informal request after delivery.

The February 2027 deadline makes these discussions timely, particularly for products still in development. The earlier the requirements are agreed, the less likely they are to create avoidable engineering changes or documentation gaps later.

Frequently asked questions

Does the EU battery passport apply directly to a PCBA manufactured in China?

Not simply because the board is manufactured in China for a European customer. The passport obligation described by the European Commission rests with the economic operator placing the relevant finished battery on the EU market. A PCBA supplier may need to provide supporting component and production information under the customer's requirements.

When do the new battery-removability derogations enter into force?

Commission Delegated Regulation (EU) 2026/1770 was published on 22 October 2026 and enters into force on 11 November 2026. The general end-user removability requirement applies from 18 February 2027. The relevant exceptions and conditions should be checked against the legal text for each product.

Does the battery-passport access consultation change the February 2027 deadline?

The consultation concerns access rights to parts of the passport data. It is a separate process from the stated 18 February 2027 start date. The implementing act was planned for adoption in the fourth quarter of 2026, based on the consultation information available at the time of writing.

Are medical devices exempt from the EU battery removability rules?

Not as a whole. The delegated regulation lists professional medical imaging, radiotherapy and in vitro diagnostic devices among the categories covered by a derogation. Whether a particular product qualifies depends on the applicable category and legal conditions. Other requirements under the legislation relevant to that product may still apply.

What should I request from a PCBA factory to support battery traceability?

Start with the records relevant to your product: component lot numbers and date codes, sourcing and authenticity checks, approved substitutions, and applicable inspection and test results. Agree on how these records are linked to the production batch and how long they will be retained.

Sources

Commission Delegated Regulation (EU) 2026/1770, 14 July 2026, published in the Official Journal on 22 October 2026.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202601770
European Commission — Digital Product Passport for Batteries (Battery Passport).
https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
Commission Implementing Decision (EU) 2026/1736, 14 July 2026.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202601736
European Commission — Batteries: access rights to certain parts of the battery passport.
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16473-Batteries-access-rights-to-certain-parts-of-the-battery-passport_en

Editorial note: The consultation dates and planned adoption timing should be checked against the latest Commission information before publication. This article is a practical overview, not legal advice.