Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries
Article 11
Removability and replaceability of portable batteries and LMT batteries
1. Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product. That obligation shall only apply to entire batteries and not to individual cells or other parts included in such batteries.
A portable battery shall be considered readily removable by the end-user where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product.
Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those products are accompanied with instructions and safety information on the use, removal and replacement of the batteries. Those instructions and that safety information shall be made available permanently online, on a publicly available website, in an easily understandable way for end-users.
There's an exception for "appliances specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion, and that are intended to be washable or rinseable". This ring is described as water-resistant, so I wonder if it would be allowed?
From my reading, the conditions seem to apply to the environment it primarily operates in, not the product itself. So the product primarily operates in the environment of the hand, and the hand is definitely "regularly subject to splashing water".
I hate to be the person to break it to you, but you're in the wrong subthread and none of what you wrote matters, the context is specifically about the regulation. There is a bunch of other subthreads where people moan about that this doesn't have any actual market.
I’m fully aware that the context is about the regulation.
But this thread is like pointing out that the cybertruck doesn’t meet EU regulations. It doesn’t matter because the truck is a sales disaster in its most potent market and will probably be discontinued.
Ok, so the discussion isn't interesting to you because you think another thing will make the second thing irrelevant. But obviously discussing the second thing has value, regardless of your personal opinion, so why don't you just stay out of the topic instead of trying to change it to something else?
> so why don't you just stay out of the topic instead of trying to change it to something else?
“Because this thread is currently higher up the page than the threads talking about what they want to talk about, so they'll get less attention” would be my guess.
Now you’ve started the meta-topic of my change in topic. This is illegal because your royal decree said that topics can’t change or evolve at all.
I propose we change the subject to how you’re the king of this website and you alone determine the topic of discussion. Would that be okay with you, Dear Leader?
This issue of replaceable battery is not only irrelevant because the product is going to fail, it’s irrelevant because it clearly complies with EU law. If it doesn’t you have to explain how the Apple Watch is legal in Europe with a battery that Apple themselves don’t replace in their stores, opting instead to users an entirely new watch.
> irrelevant because it clearly complies with EU law
Why is that so clear? Multiple other comments in this submission will point you to the exact parts from coming regulations that it doesn't seem to comply with at all, if I recall correctly it'll start being enforced in 2027. So if Apple wants to continue selling their watches in Europe, they'll have to follow that too, and since they've been aware of it for quite some time already, I'm sure they already have plans and actions in motion for doing just that.
Or Apple will throw a hissy fit¹, stop selling them directly here, but get the sales anyway as people will buy them elsewhere and import to sell on the grey market.
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[1] Though last time they did that, disabling existing features in response to the app stores decision, they backed down PDQ, so maybe that threat would have no weight.
For something like a smart ring, a user-replacable battery is just totally impractical. Particularly if you want any sort of water resistance. The thing is just too damn small and will require special tools no matter what.
I don't think it's at all reasonable to expect such a product to have a user-replacable battery without doubling the cost. Sure it'd be nice, but the reality is sometimes it just isn't possible to accommodate.
We regularly get contacted by people in Europe who want to buy our product, but we haven't been providing support due to the cost of certs, and other regulatory needs (medical/wellness device).
We want to help people in the EU, but with laws like replaceable batteries, it's going to push us further and further away from being able to do that.
Our product is designed to be refurbished, but not user-replaceable.
At the same time, how many products do people give up on because of battery life, and is this a non-issue with future battery chemistries?
Do people replace their phones because the battery isn't good anymore, or is it more likely they've broken the screen, cameras, etc to the point where it doesn't make sense to replace those anymore? Or they just want the newest thing?
> Do people replace their phones because the battery isn't good anymore, or is it more likely they've broken the screen, cameras, etc to the point where it doesn't make sense to replace those anymore? Or they just want the newest thing?
This is why repairability isn't restricted to just the battery. And buying the newest thing every year is kinda frowned upon here in the EU now. I'm sure some people still do it but most people aren't flashing their new phone around anymore. And phones have become boring anyway. The latest Samsung S25 is mostly the same as the S23, exact same form factor, cameras. Just a bit faster and a bit more memory.
But the government sets a baseline here to stimulate sustainability. I really agree with it, this planet has to be usable for a lot longer. And economic growth isn't everything.
We have to move away from consumerism for the sake of it and I think we're making good inroads here in the EU. Not to mention it means there's more money left over for important stuff like doing things with friends.
Anecdotally, 2023/24 all media in Germany was full of ads for shops trading refurb phones. Most of those talked lower prices, but some mentioned sustainability.
The first article does not look to be informative; it values the EU smartphone market at around 465 million USD, which is impossibly low. If you assume a smartphone is valued at $1,000, a market of that size would only amount to 465,000 devices sold; this is around 0.01% of the EU’s population.
The second article links to a paper which appears to be more informative (though it has not been peer reviewed):
> For example, in the United States, the average expected life span (replacement
cycle length) of consumer and enterprise smartphones was 2.67 and 2.54 years, respectively, in 2023, while in the UK almost 30% of surveyed consumers use their smartphone up to two years and 41% up to 4 years.
and
> Furthermore, evidence shows that European, American and Chinese consumers have reduced the replacement rate of their smartphones, increasing their average life cycle (see Figure 1). These data suggest that consumer preferences are changing, and new opportunities arise for companies who want to find new profitable ways to meet the needs of their customers.
Those numbers would be more realistic, amounting to around a thousand dollars spent per each EU citizen per year; this seems a little high if replacement rates are hovering around 3 years on average, but not impossible like the other figure.
What I don’t understand is why it would be written “USD 448.87 million.” This convention is common in accounting and finance as well, but they usually make an indication of it in a column header.
> Is there any evidence that Europeans aren’t buying new phones at the same rate that they used to?
I bet it is the case, not because it is frowned upon, but because tpeople have less money, the prices of phone increased a lot and the increase of performance and usefulness is plateauing.
> We want to help people in the EU, but with laws like replaceable batteries, it's going to push us further and further away from being able to do that.
We want to help people, but only if and when it’s profitable for us to do so on terms we decide for you.
That's not what a lot of proponents of these laws argue. They often state that if a company is making something unavailable in the EU due to one of the laws that the company is throwing a fit or being spiteful.
Yes its perfectly fine, thats my point. They arent spiting the EU, they are just responding to the legislation by not entering that market. If EU voters are unhappy they can take it up with their government.
Yes, a free market isn't the answer to everything. It will never optimise for sustainability unless this is a conscious consumer choice factor. It's way too important to leave it to that though. Hence regulation.
Just change the underlying economic incentives - but nobody is even barely there yet, except maybe the EU. Doughnut Economics, when are you going to save us (& the planet)?
That's an unfair representation of the situation. There's nothing about this device that implies "disposable". The EU is definitely the problem here. I think the problem is the EU loves legislating entrepreneurial creativity into the dirt.
> Do people replace their phones because the battery isn't good anymore
Pretty much exclusively? The last 4-5 iPhone purchases in my family have all been due to dying batteries (plus a couple of off-brand battery replacements by local cellphone techs).
Nothing else on iPhones really ever breaks, provided you keep some sort of case on it. The only non-battery failure I've ever had was a corroded lightning port (on a iPhone that was regularly used in a salt-chlorine swimming pool). And of course a couple of replacements due to critical banking apps that have drop support for old iOS versions...
And what did you do with them? Throw them away? I bought and used an iPhone 11 for a year last year, and it came with a perfectly functional, replaced battery.
People on HN have such a blind spot around old, used phones which thrive in secondary marketplaces. You'd think iPhones are filling dumpsters with the rhetoric here but they actually hold their value remarkably well, which means they have a much longer useful life. A replaceable battery is different from a user-replaceable battery. The former is a sustainability concern, the latter is just a feature.
The ones that aged out of running needed software are still sitting in a cabinet somewhere. A couple of the others were killed off when their battery pack swelled, and another didn't survive a local tech's efforts to replace the battery...
With batteries that could be replaced without delaminating the whole device, (and ideally, an open boot loader), I'd be able to make use of most of them.
Speaking personally, I've never broken/damaged a phone. Since the Pixel 1 started requiring removal of the screen in order to swap the battery, 100% of my phone replacements have been because the battery isn't good anymore. (Granted, I would've gotten a new phone eventually regardless, when the old one stopped receiving security updates.)
BTW this also works the other way: I find myself to avoid US products more and more because they tend to come with inbuilt obsolescence, or, for digital products, with dark patterns preventing subscription cancelling.
I'm not who you asked that question, but I'd guess it's because it requires "proprietary tools, thermal energy, or solvents to disassemble the product."
It'd be hard to design/manufacture a device that reliably remains waterproof after a typical not-specially-skilled owner opens it up to replace a battery. It's really common to hear of people damaging watches due to water ingress after battery replacements, getting seals or orings seated just right isn't something every user is going to be able to do.
I can imagine some medical devices have similar sealing requirements, perhaps even more robust sealing methods since they might need to be exposed to regular disinfection grade cleaning with chemicals harsher then just water. I could easily understand why a company may design a medical device that its heat-glued together for sealing purposes in a way that can only reasonably be done (and redone) at the factory.
I killed an original Pebble when I Dremelled it open to replace the battery, and failed to hot glue seal it well enough and it got wet inside.
Having said that - I dislike this design choice for the Index 01. I can see myself becoming reliant on this right before they sell out to Garmin or whoever and tell all their customers to FOAD again. Trust is very hard to win back.
> I can see myself becoming reliant on this right before they sell out to Garmin or whoever and tell all their customers to FOAD again. Trust is very hard to win back.
This product is perfect for that case, though: you have to decide to buy another one each time the battery runs down, which aligns seller incentives with the user/purchaser. The danger cases are mainly when the seller gets up front money and then has to provide something indefinitely.
> Do people replace their phones because the battery isn't good anymore
Yes. I'm not bothered about the latest thing, and every phone I've replaced has been because of two things: the battery has degraded until it's unacceptable, or it no longer gets OS updates.
> We regularly get contacted by people in Europe who want to buy our product, but we haven't been providing support due to the cost of certs, and other regulatory needs (medical/wellness device).
I understand your point but being safe is not an option
> Do people replace their phones because the battery isn't good anymore
I just had to change the battery of my phone, and I wish that it would have been just a swap to do. Actually because it wasn't, I add to buy a temporary phone the time I needed to have the parts and the tools
I may not be a typical user, but I've run my last few iphones and macbooks until the battery gave up the ghost. I haven't really needed more features or raw horsepower for quite some time, so the battery ends up being the limit I hit.
iPhones and MacBooks can be serviced to replace the battery.
My iPhones typically get a fresh battery around the 3-year mark, or whenever the battery health dips below 80%, and do a second tour of duty with someone in the family. In all cases so far, the OS goes out of support and apps stop working before the second battery degrades.
In my last two phones I had to replace the battery 2 and 4 years in. One because it swelled, the other because it couldn't hold charge. Both cases I got a few extra years of usage from the phone. I'm in the EU, and I support this sort of regulation.
> We want to help people in the EU, but with laws like replaceable batteries, it's going to push us further and further away from being able to do that.
All I could think of was "Wow, the regulation works better than expected".
It's incredible the other side think of themselves as "We want to help people in this environment we don't understand, but receiving pushback" and yet they don't want to adjust, no, it's the environment that is wrong, even if it's built up by people.
My personal experience: Electric toothbrush and razor. I especially hate the razors, you can replace the head, they could last a lifetime, but the battery is practically dead after two years. Toothbrushes are improving, the last one has 3 years of service and still work ok.
I don't think it will be possible to make wireless earbuds or a ring with replaceable batteries without seriously compromising the ergonomics of fitting onto or into the human body.
I have a pair of earbuds designed to be as diminutive for sleeping comfortably and I have no idea how you would do that with a replaceable battery even if Airpod sized devices can be done.
My main concern here is that i live in an area that regularly get's below -20° and my electronic devices are regularly dying around me. And while I try to keep my hands warm-ish, they do get cold sometimes, and it would suck if a non replaceable battery died on me early because of this.
What has been long considered one of the most wealthy markets is a country descending into a billionaire controlled kleptocracy. And they're pissing off every other country in the world with tariff blackmail and punishment (or extra judicial executions) for any country that fails to bend the knee and fawn obsequiously enough to their leader.
One of the most populous markets is a country that manufactures approximately 100% of all consumer electronics, and will have a hundred versions of this available for 10% of Pebble's price on AliExpress as soon as it shows any signs of gaining market traction anywhere (quite likely stolen or "3rd shift" ones from Pebble's own outsourced production line).
India, who these days has more than enough local skill and experienced ex-H1B tech people to create this from scratch at home (and at least some with a deep resentment over how they were treated by US tech companies while they were there)?
One of the no longer EU markets is suffering post Brexit austerity and isn't likely to be buying a heap if tech toys - even if their fucked up new importing goods paperwork doesn't make it impossible to get your product into the country.
There goes about 40% of the planet's population.
That leaves, what? Manufacture locally and try surviving by selling to the US market at prices driven by US labor costs which'd make the product prohibitively expensive globally? South East Asia, who're likely to buy the Samsung copy over one from a US company? Russia, who (at least for now) is under trade sanctions for a US based company like Pebble? So perhaps Canada (until their southern neighbour make good on their threat to try and make them the 51st state)? South Africa? Australia and New Zealand?
While I sympathize with the intent of the law, this is a great example of why it's dumb. There's no possible way you could make that ring, in a reasonably ring-sized form factor, with today's manufacturing processes in such a way that an end user could replace it.
If this law pushes back against the idea that it's ok to make endless tech products which are essentially future rubbish as soon as you buy them, then I think that's a good thing. Perhaps products like this just shouldn't exist until we have better ways of dealing with the remains.
The problem is that it makes it impossible to have a version 0 to iterate on until a whole lot of other industries have advanced. Imagine the situation of in-ear hearing aids: they shouldn't be allowed to exist until they're perfect, unless we're happy telling deaf people they have to wear much larger than necessary devices and advertise their disability.
I'm glad we're reducing e-waste. I'm not thrilled about the idea of saying you can't make a thing until 100% of the bugs are worked out, meaning you can't have a beta version for research and fundraising, meaning, you can't conjure the perfect version into existence.
Fortunately, your link basically says it doesn't apply to something you wear on your hands or arms:
> By way of derogation from paragraph 1, the following products incorporating portable batteries may be designed in such a way as to make the battery removable and replaceable only by independent professionals:
> (a) appliances specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion, and that are intended to be washable or rinseable;
But the only mention of "medical" comes right after it, and doesn't include hearing aids, future smart glasses, etc.:
> (b) professional medical imaging and radiotherapy devices, as defined in Article 2, point (1), of Regulation (EU) 2017/745, and in vitro diagnostic medical devices, as defined in Article 2, point (2), of Regulation (EU) 2017/746.
So ironically, the law allows disposable "junk devices" people are complaining about here, but doesn't allow factory-only serviceable hearing aids. How 'bout that? We can buy our smart rings and throw them away, but hearing aids will have to remain giant hunks of heavy plastic, or at least the models purchasable by average people who can't fly out of the EU to buy the good ones.
Edit: It's easy to downvote. I cited the relevant law. If I'm wrong, cite other law that explains why.
Hearing aids have had replaceable batteries since they were invented basically. I still remember my grandma 20 years ago fiddling with the small batteries, so that really is not a problem.
If you want more freedom to design medical devices for people where there is an actual need, it would easily be done by expanding the exception for medical devices that already exists in the law.
If you think people to be able to sell unsustainable and mostly superfluous electronics because any improvements there might eventually trickle down to hearing aids, your argument is basically "we should accept the millions of tonnes of unnecessary e-waste in order to get slighly smaller hearing aids", which think many reasonable people would disagree with.
If the battery lasts for two years its exceeding the useful life of many other products already, some of which of have higher environment cost for manufacturing and disposal.
The law has chosen poor proxies for lifespan and impact.
The problem with plastic straws was properly disposing them. For a piece of jewelry I doubt many people would throw it away on the side of the road. A ring that last for years is different than a disposal product that people may use for a couple of minutes.
Products are supposed to last two years at the very least in EU (local laws may be more strict, but not less). If your product dies before that time, the customer will cite warranty, and there you go. This device is likely one of the many 'designed to last a little bit more than two years', with the emphasis on 'little bit'. It appears to be a perfect example of planned obsolescence.
Who gets to choose what products are future rubbish?
Even if you think this product is a waste of resources, why is THIS waste of resources something we should stop, but not other, bigger wastes? Should we outlaw flying somewhere when you could take a train? The fuel spent on a short flight wastes way more resources and damages the environment much more than this smart ring does. If we are willing to ban this piece of tech because it is a waste, couldn't the same arguments be made about a short range flight?
If their official sizing kit 3D models are accurate(better be!), there's exact amount of space for an SR721W watch/hearing aid silver oxide coin cell. And these are not even the tiniest of standardized replaceable batteries.
You're too generous. I feel like the entire production run of this ring could be equivalent to a single discarded washing machine. This law is hamfisted.
I understand that sentiment but I think its arbitrary. People buy lots of products that don't have a useful life exceeding two years. For example, every pet toy ever sold. Some will have higher impact for manufacturing and disposal than this ring.
1. Arbitrary it may be. You have to start somewhere. In that sense, anything we do is “arbitrary“. Straw man. (see also: ban of plastic straws)
2. I would expect pet toys to be regulated as well and to contain less environmental toxins and hard to recycle elements than batteries, so I doubt the claim about impact per item sold.
As long as their batteries are replaceable, that’s fine, and if not, they will not be legally allowed to be sold in Europe. What point is it that you’re trying to make?
> So people should make their own choices about the products they buy?
A little, yeah. Buy and don't use: your problem. Buy and can't use because I can't change the battery: subject to regulation. We can't stop anyone from making dumb monetary decisions, but we can stop products not being repairable.
And an endless stream of devices in the form of toys running full software stacks which never receive updates. Great, some products are as shitty. Perhaps we oppose those as well?
Article 11
Removability and replaceability of portable batteries and LMT batteries
1. Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product. That obligation shall only apply to entire batteries and not to individual cells or other parts included in such batteries.
A portable battery shall be considered readily removable by the end-user where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product.
Any natural or legal person that places on the market products incorporating portable batteries shall ensure that those products are accompanied with instructions and safety information on the use, removal and replacement of the batteries. Those instructions and that safety information shall be made available permanently online, on a publicly available website, in an easily understandable way for end-users.
[…]
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A...
(This is active law; there is however a grace period for products until 2027.)