European Commission Proposes Changes to Removability and Replaceability Rules for LMT Battery Cells

The European Commission has published Omnibus VIII, a targeted legislative proposal that includes an important correction to the EU Battery Regulation affecting light means of transport (LMT) batteries.

Under the current Regulation (EU) 2023/1542, LMT batteries must be removable and replaceable at cell level. In practice, this requirement raises significant safety concerns, as replacing individual cells increases the risk of battery failure, fire, and thermal runaway.

What the Commission proposes

Omnibus VIII would replace Article 11(5) with a new provision requiring that LMT battery packs remain removable and replaceable, but replacement occurs at module level rather than cell level.

This approach maintains repairability while aligning EU law with established battery safety practices.

State of play

• The proposal has been adopted by the European Commission.
• It has not yet been treated by the European Parliament and Council.
• Until amended, the current Battery Regulation remains fully applicable.

LEVA-EU perspective and member support

For LEVA-EU, this proposal is a necessary and pragmatic adjustment that better balances safety, repairability, and technical feasibility. LEVA-EU will continue to monitor developments and engage with policymakers to support swift adoption of the proposed change.

To support its members in the correct interpretation and application of the complex Battery Regulation, LEVA-EU is actively working through its Battery Working Group, where members:

• Exchange technical and regulatory insights on battery design and compliance,
• Discuss practical implications of current and proposed EU rules,
• Coordinate industry positions ahead of legislative discussions in the European Parliament.

Furthermore, LEVA-EU is member of the European Commission’s Waste Group, where in-depth consultations take place between the Commission, Member States and Stakeholders on the interpretation and further implementation of the Battery Regulation. This provides LEVA-EU with a direct line to the Commission for any question that doesn’t get resolved in the Battery Working Group.

For all further details on LEVA-EU’s Battery Working Group and on LEVA-EU membership in general, please contact LEVA-EU Managing Director Annick Roetynck, annick@leva-eu.com.