Published 2026-11-07, updated 2026-11-07, by the Maclean team in Suzhou

EU Battery Regulation 2027: What to Ask Your Floor Washer Factory

Short answer: From 18 February 2027, Article 11 of Regulation (EU) 2023/1542 requires that the battery in a product such as a cordless floor washer or stick vacuum can be removed and replaced by the end user with commercially available tools. There is a derogation for appliances used in wet environments, with strict conditions. Ask your factory about the battery design of each model before you plan your 2027 orders.

If you import cordless floor washers, stick vacuums or spot cleaners into the EU, the battery rules change in February 2027. This guide sums up what the regulation says, which dates matter and what to ask your factory. We read the regulation and the Commission guidelines on EUR-Lex. This is not legal advice, so check your own case with your compliance adviser or test lab.

Which batteries the rule covers

The regulation calls a battery portable when it is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is not an electric vehicle, LMT or SLI battery. The battery pack in a household cordless floor washer or stick vacuum usually falls in this group.

What Article 11 asks from 18 February 2027

The end user can remove and replace the battery at any time during the lifetime of the product. The rule covers the entire battery, not the single cells inside it.
Readily removable means with commercially available tools. Specialised tools are allowed only if they come free with the product. Proprietary tools, heat and solvents are not allowed.
The product comes with instructions and safety information on the use, removal and replacement of the battery. The same information stays online on a public website.
Replaceable means another compatible battery can go in without affecting the function, performance or safety of the appliance.
Batteries stay available as spare parts for at least five years after the last unit of the model is placed on the market, at a reasonable and non-discriminatory price.
Software must not be used to block a compatible replacement battery.

The derogation for wet appliances

Article 11(2)(a) allows a battery that only independent professionals can replace, for appliances specifically designed to operate primarily in an environment regularly subject to splashing water, water streams or water immersion, and intended to be washable or rinseable. It applies only where it is required for the safety of the user and the appliance.

A floor washer works with water, so importers ask whether it qualifies. The Commission guidelines (C/2025/214) list five indicators, and all of them are relevant:

Specifically: the main purpose of the appliance is to operate in that environment.
Primarily: it is the environment for the majority of the active service of the appliance.
Washable or rinseable: the appliance is intended to be washed or rinsed.
Compromising safety: the product documentation shows that removal by end users would compromise the safety of the user or the appliance.
No way to redesign: the documentation shows that the appliance cannot be redesigned with current technology without harming safety, performance or function.

The guidelines link splashing water to IPX4, water streams to IPX5 and IPX6, and immersion to IPX7. They also say an IP rating does not show whether a redesign is possible. Their examples are oral hygiene appliances and epilators, and they are the Commission's view, not legally binding.

The guidelines do not name floor washers. The safer plan for 2027 is a battery pack the end user can change, unless your adviser confirms the derogation for your model in writing.

Other dates in the regulation

From	What applies
18 August 2024	Conformity assessment of batteries (Article 17 and Chapter VI)
18 August 2025	Separate collection symbol on all batteries (Article 13(4)), and the producer obligations for waste batteries (Chapter VIII)
18 August 2026	Battery label with general information and capacity (Article 13(1) and (2)), or 18 months after the implementing act, whichever is later
18 February 2027	Removable and replaceable portable batteries (Article 11)

Under Article 3(47), a producer can be an importer that supplies batteries for the first time in a member state, including batteries inside appliances. Producers register in each member state where they first make batteries available (Article 55). Check with your adviser which of these duties fall on you.

Questions to send your factory

Copy these into your inquiry and ask for written answers per model:

1. Can the end user remove the battery pack of this model with commercially available tools, without heat or solvents?
2. Is the battery a separate pack with a connector, or is it wired inside the body?
3. Will you supply replacement battery packs for at least five years after our last order of this model?
4. Does any software or battery check stop a compatible replacement pack from working?
5. Can you give us instructions for removing and replacing the battery, for our manual and our website?
6. What IP rating does the model have, and which test report shows it?
7. Can the battery carry the separate collection symbol and the capacity label we need?

How we handle it

We are the factory, so our engineers answer battery questions for each model directly. Tell us the model and the market, and we reply in writing together with the quotation. See what to send before you ask for a quote and our floor washers.

Sources: Regulation (EU) 2023/1542, Articles 3, 11, 13, 55 and 96, and Commission notice C/2025/214, both on EUR-Lex. Read in November 2026.