Use the legal rule as a review starting point, not a catalog claim
Article 96(2)(a) sets 18 February 2027 as the application date for Article 11. A portable battery is sealed, weighs no more than 5 kg, is not specifically designed for industrial use and is neither an EV, LMT nor SLI battery. The general Article 11 rule concerns end-user removal and replacement of the whole battery. It addresses access tools, online instructions and safety information, compatible replacement, spare availability for at least five years after the last equipment-model unit is placed on the market, and software restrictions. The wet-appliance route is conditional: primary use must regularly involve splashes, streams or immersion; the appliance must be intended for washing or rinsing; and professional-only replacement must be needed for user and appliance safety. Ask qualified EU reviewers to determine scope and any exception for the exact version and market date.
Before approving a market version, have the responsible reviewer record the current applicable Official Journal instrument, its effective date and the basis for any claimed exception.
Give the design review one of three honest outcomes
Use these as purchasing statuses, not legal approvals. The reviewer should sign the conclusion for the identified design revision and list the evidence behind it.
1. Construction is still unknown
If only a model photo, capacity field or generic supplier statement is available, leave the replacement route unresolved. Request the current battery and enclosure records before treating a quoted sample as the final EU version. Record any feasibility work separately from the base product quotation.
2. An end-user route is proposed
Ask the supplier for revision-linked access documentation and replacement information. Have the responsible reviewers check the proposed route against the applicable rules and product-safety file. A demonstration on a different housing, connector or battery revision should not close the ordered version's review.
3. A professional-only route or exception is claimed
Request the precise legal basis, the evidence supporting the claimed conditions and the responsible reviewer's decision. A pump's water-related name, a sealed appearance or a service technician's ability to open it is not enough. Keep the claim pending if the relevant law, design evidence or responsible reviewer is unidentified.
Create a replacement-design record that can travel with the RFQ
Use one row set for each model and revision. Record the actual document reference, evidence date, reviewer and open item; do not replace those fields with an unchecked yes/no answer.
| Record | What to request | How it changes the purchasing decision |
|---|---|---|
| Market and design identity | Destination Member States, intended placing-on-market date, product model, sample ID, enclosure/PCB revision and cell or pack identity. | Establishes which proposed commercial version the review covers; stops a conclusion being transferred between visually similar models. |
| Battery scope | Battery label and specification, chemistry, weight, supplier/model identity and the qualified reviewer's classification. | Keeps an unidentified battery open; the fact that an appliance is hand-held is not a classification record. |
| Access documentation | Controlled diagram or safe service record showing access sequence, fasteners, connector and tools; state any heat, solvent, proprietary or specialised tool requirement. | Identifies whether the proposed access route needs further engineering or evidence. Do not ask an untrained buyer to open a battery assembly. |
| Replacement identity | Proposed replacement code, dimensions, connection, protection and any pairing or software condition; identify who reviews compatibility. | Separates a named supported replacement from an undefined similar-looking cell or pack. |
| Instructions and support | Controlled instruction version, language plan, public-document location, spare ordering route and the responsible support party's written supply plan. | Allows the buyer to assess the support scope rather than assume that a product quote includes an ongoing replacement program. |
| Claim and review owner | Applicable legal reference and revision, supporting design evidence, reviewer, review date, outcome and remaining conditions. | A supplier's route claim stays a request for review until its basis and evidence are reconciled. |
| Quotation and change control | Separate product, proposed design work, spare/service support and evidence tasks; list approvals needed after any battery, enclosure, connector or software change. | Prevents unlike scopes being compared as one unit price or an earlier review silently covering a changed version. |
The record is complete only when its open items have owners and the documents describe the same proposed order version. Completing the worksheet does not itself establish conformity or authorize placing the product on the EU market.
Start from two published models without assigning a replacement route
These examples show how to ask a better design question from an existing catalog record. They are not two approved EU designs, and no internal battery construction is inferred from their product images.
K01 / Catalog P278
K01 publishes a 400mAh battery field and a 4-5.2V charging field. Neither identifies the cell or pack, enclosure access, supported spare or replacement procedure. For an EU project, request those records against the current K01 sample rather than copying a replacement conclusion from another appliance.
JLB-W09 / Catalog P179
JLB-W09 publishes Battery: 800mAh and Power: 5V-5W. These fields do not identify battery access or replacement support; the power field is not confirmed as battery nominal voltage or charging input. Its water-dispenser purpose does not establish an exception. Ask for the current design and the review basis, not a blanket exemption statement.
Battery chemistry, weight, classification, access construction, replacement compatibility, spares and legal route remain unconfirmed for both published examples. Capacity is not a runtime, service-life or EU-readiness claim.
Attach the unresolved design question to the model inquiry
Choose the exact model, then use its existing quotation request linked above or on the model page. Keep the model, quantity, destination country, channel, OEM scope and port together. Add the following request to Execution and inspection notes; fill the buyer-supplied fields rather than leaving a generic EU-ready instruction.
For [model / catalog reference], our intended EU markets are [Member States] and the planned placing-on-market date is [date]. Please identify the current product and battery revisions and provide the available battery label/specification, access documentation, proposed replacement identity, instruction/support records and the basis for any proposed professional-only route or exception. Mark unavailable records and design changes as open items, with their quotation scope, before we approve the proposed EU version.
Yaoyuan supplies factory direct for wholesale projects only; MOQ starts from 1000 PCS. Product and any agreed support or development scope are discussed through a private quotation. This request does not promise an available replacement design, certification, stock or delivery date.