The Batteries Regulation and shoemaking

Considering the European Batteries Regulation and its likely impact on the footwear industry.

by Nicola Pichel-Juan

The European Union’s Batteries Regulation 2023/1542 may not immediately seem to have any relevance for the footwear industry and, indeed, it will not be applicable to the vast majority of footwear products. However, for shoes incorporating batteries – in particular children’s light-up footwear – it could have far-reaching and costly implications.

What is the Batteries Regulation 2023/1542?

The regulation entered into force on 17th August 2023 and aims to minimise the environmental impact of batteries throughout their lifecycle, including their collection, recycling and repurposing. This in turn impacts any products incorporating batteries. The stated aims of the regulation are to achieve i) circularity, ii) design-stage responsibility, iii) reduced environmental impact, iv) supply chain transparency and v) harmonised rules across the EU.

How could this impact footwear?

Article 11 of the regulation states that ‘products incorporating portable batteries shall ensure that those batteries are readily removable and replaceable by the end user’. In addition, products incorporating portable batteries must be ‘accompanied with instructions and safety information on the use, removal and replacement of the batteries.’ A portable battery is generally defined as a sealed battery weighing 5 kg or less that is not specifically designed for industrial use. This applies to any products being placed onto the EU market on or after 18th February 2027.

Most children’s light-up footwear encapsulates the battery and the rest of the electronic workings in the outsole unit, which will typically be covered by a Strobel board. The products have deliberately been engineered so that the batteries cannot be accessed or removed by the end user, and there are some very valid reasons for this. Firstly, the electronics are completely protected from water and dust ingress, which could stop them from working. It is also an important safety consideration for children’s footwear to ensure that the battery cannot be accessed and ingested.

However, this does make footwear containing batteries significantly more challenging to recycle. It will not be accepted into electronics recycling processes as it is not an electronic item. Conversely, it will not be accepted into the (limited) footwear recycling facilities due to the fire risk associated with the batteries. With a general drive towards product circularity, children’s light-up footwear presents a considerable challenge from a circularity and end-of-life management perspective.

Exemptions to the regulation

A draft delegated act supplementing the regulation was published on 28th April 2026 and made available for consultation. The draft proposed a number of derogations from the main regulation. This would allow specific products to be designed in such a way that the battery is removable and replaceable only by independent professionals (rather than by the end user). These include the following:

1. Appliances, including wearable devices, 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.
2. Professional medical imaging and radiotherapy devices.
3. Wearable devices, for which the safety, durability or water resistance may be compromised by user access to the battery – or that rely on a compact sealed enclosure to maintain functional integrity, including protection against dust and shock.

A number of companies and industry associations submitted feedback in support of an exemption for footwear.

Current position

Following the consultation period, the European Commission formally adopted the delegated act (EU) 2023/1542, setting out specific derogations for battery removability and replaceability, which does not include an exemption for footwear. SATRA believes it is unlikely that it would be possible to claim that footwear meets derogations for either wearable devices or products used in water, a key counterargument being that the electronic function (lights) is ancillary to the primary function of the footwear.

Why does the EU require batteries to be removable and replaceable?

The information below highlights some of the key driving factors for the EU requiring batteries incorporated into finished products to be removable and replaceable.

Removability:

Relevant to end-of-life management of products

Facilitates safer recycling

Allows minerals and resources to be recovered

Replaceability:

Supports goods staying in circulation for as long as possible

Products may be prematurely discarded if the battery stops working

It is also important to note that even with a derogation, the battery would still have to be removable and replaceable. The derogation simply allows this process to be carried out by an independent professional, rather than being something that can be readily done by the end user.

At the time of writing this article, it therefore seems extremely likely that footwear will have to comply with the regulation from 18th February 2027. SATRA will continue to monitor the situation and will share any further updates as they become available.

Design and cost implications

Assuming that footwear containing lights does have to be re-engineered to allow for access to replace the battery, this will clearly have significant design and cost implications for the companies selling those products.

A key challenge that organisations will face is the ability to balance several potentially conflicting requirements. Organisations will need to ensure that:

• batteries can be accessed
• water and dust ingress is prevented
• batteries cannot easily be accessed by children
• comfort is not affected
• the functionality of the footwear and the electronics are not compromised.

A potential option to consider is keeping the battery compartment within the outsole cavity but making the battery itself accessible through a cover that can be removed by a screwdriver. However, this would likely mean that access would also be needed through the insole or Strobel board. It would also not be a viable solution for wellington boots or moulded sandals.

The future

Going forward, in light of the implications of this regulation organisations will need to consider how technically viable and cost effective it is for compliant alternatives to be produced.

Although the regulation does not directly affect countries outside the European Union (with the exceptions of Northern Ireland and Gibraltar), it is likely that other areas will introduce equivalent regulations in order to support repairability, recyclability and broader circular objectives. It is anticipated that the UK will start a review of its battery regulation in the last quarter of 2026 and the approach generally being taken at the moment appears to be alignment with the EU.

Publishing Data

This article was originally published on page 10 of the September 2026 issue of SATRA Bulletin.

Other articles from this issue »

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