Effective from January 1st, 2025, the France WEEE and Battery regulations introduce new modulation criteria concerning the battery removability and replaceability of portable batteries and Light Means of Transport (LMT) batteries. This criteria aims to address the environmental impact of products containing batteries by issuing penalties for those devices affected.
This is the latest eco-modulation criteria to be applicable for household electronic devices in France since its introduction in 2010, and for professional devices, under the eco-modulation fee model in France since 2019. Eco-modulation is used as an incentive tool aimed at promoting a circular economy using a fee scale linked to the repairability, reuse, depollution, recyclability, and lifespan of household electrical products.
The definitions for the criteria for battery removability align with those of the EU Battery Regulation 2023/1542. Products that are not subject to this penalty are those that contain batteries which are ‘easily removable by the end user’. This includes products where:
- Batteries can be removed using commercially available tools.
- Batteries can be removed using specialized tools which are provided free of charge along with the product.
- Proprietary tools, thermal energy, or solvents are not needed in disassembly.
As an exception to the end-user separation requirements above, it is acknowledged that certain products may be designed so that the battery cannot be removed by the end-user, or that are designed to only be removed/replaced by professionals. These exceptions include:
- Devices designed to experience regular water exposure (only applicable when required to ensure the safety of device and user).
- Professional medical and radiotherapy devices.
Please note: any exemptions must be validated between professional federations (such as sector/industrial group associations) and compliance schemes.
For any devices concerned by the above new modulation criteria, it is expected that producers will be requested to provide documentation describing the necessary steps to remove the battery safely. This will be used to justify if the penalty can rightly be omitted from these products.
Without proper documentation, all devices will be considered as ‘including inseparable batteries’, and as of January 2025, be subject to these penalties.
If you need support or have any questions, please contact us at CGlobal-Sales@landbellgroup.com.
Published July 22, 2024
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