Euralarm urges Commission to include smoke, carbon monoxide and gas alarms for exemption from Article 11(3) of the EU Batteries Regulation

These products should meet the following criteria:

• Life Protection: Explicitly designed to protect human lives within living environments.
• EN Product Standard: Tested and approved according to valid EN standards.
• 10-Year Battery: Powered by a portable battery that reliably supplies the device for at least 10 years.
• Recycling Safety: Easily removable batteries to ensure safe handling in recycling centers.

Only products meeting all four conditions should be considered for inclusion.

Background

While it is often beneficial to have portable batteries that users can remove and replace using commercially available tools throughout the product’s lifespan, there are cases where this requirement may not be appropriate and could even compromise user safety and appliance functionality. One such scenario applies to devices like smoke alarms, carbon monoxide detectors, and gas alarms.

These safety devices are designed for use in residential settings, alerting occupants to fire, smoke, or hazardous gases (especially during sleep) so they can respond appropriately and evacuate if necessary. To ensure proper operation, all these products incorporate a portable battery. Notably, a significant number of these devices in Europe (particularly smoke and CO alarms) come with permanently soldered 10-year batteries.

This category of products explicitly serves to safeguard human lives within their living environment and includes:

• Smoke Alarms (according to hEN 14604)
• Carbon Monoxide Alarms (according to EN 50291-1)
• Gas Alarms (according to EN 50194-1)

Justification

• Life-Saving Purpose: The primary function of these devices is to safeguard lives within residential environments.
• Sensor-Based Service Life: Unlike conventional product design considerations, the service life of these devices relies solely on physical sensors. It is determined by physical conditions and limits.
• 10-Year Batteries: A significant subset of these devices operates on a single battery throughout their entire 10-year service life. This level of sustainability and efficiency is remarkable.
• Permanently Soldered Batteries: Given their purpose and longevity, it is neither practical nor necessary for end-users to replace batteries. Consequently, 10-year batteries are now permanently soldered.
• Safety Risk: Introducing replaceable 10-year batteries would not only be futile but also pose safety risks similar to those associated with hearing aids.

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