A regulation, not a directive
Regulation (EU) 2023/1542 replaced the earlier EU battery directive with a regulation that applies directly in every member state. It covers batteries across their life cycle: design, substances, labelling and information, due diligence for some operators, collection, recycling and end of life. Many obligations are phased in over several years, and the dates and exemptions differ from article to article. That phasing is the main reason the regulation causes confusion: some obligations apply now, others apply later, and some depend on the battery category or the size of the company.
For smart glasses, the relevant batteries are small. Cells in the temples typically total about 85 to 235 mAh across both sides, and charging cases add a separate battery whose size depends on the design. These are portable batteries in the regulation's terms, and they are usually built into the product rather than sold loose. The regulation applies to batteries whether they are sold on their own or incorporated into a product, so the glasses and the case both bring obligations.
The battery regulation is also separate from the transport rules, although the same documents serve both. Glasses with built-in cells usually move by air as UN3481, lithium-ion batteries contained in equipment, under Packing Instruction 967 Section II when the cell is at or below 20 Wh and the battery at or below 100 Wh; IATA guidance recommends a state of charge of 30 percent or less for PI 967, as a recommendation rather than a requirement. A charging case sold as a separate accessory is judged as UN3480 or UN3481 depending on how it ships and its watt-hour rating. Compliance with one set of rules does not imply the other.
Who has to do what
The regulation places obligations on economic operators: the manufacturer of the battery, the producer who first makes batteries available in a member state - which can include the brand or importer of a product containing them - distributors and, for some duties, online platforms. For a smart glasses brand importing into the EU, the producer role is often the one that matters most, because it brings registration and extended producer responsibility for collection in each member state where the product is sold. Which role a brand holds depends on how it sells, so the role should be confirmed with counsel or a compliance service provider.
| Topic | What it involves | Where it lands in a program |
|---|---|---|
| Conformity and marking | Conformity assessment and marking for batteries as the regulation requires | Cell and pack documentation from the battery maker, held in the technical file |
| Labelling and information | Separate collection symbol, battery information, later digital labelling steps, phased by date | Box, manual and, where space allows, the product or case |
| Substances | Restrictions on certain substances in batteries | Cell supplier declarations, alongside RoHS and REACH for the product |
| Producer registration | Registration and collection duties per member state | Brand or importer, often through a compliance scheme |
| Design and replaceability | Requirements on removal and replacement of portable batteries in appliances, with dates and exemptions | Temple and case design; confirm applicability with counsel |
Documents to request from partner plants
The battery side of a smart glasses file usually starts with documents the cell or pack maker already holds. The desk asks for them at sampling stage so that the brand's own obligations can be planned around them.
- Cell and pack specification. Chemistry, nominal voltage, capacity and watt-hour rating for the temple cells and the case battery.
- Safety reports. IEC 62133-2 for portable lithium cells and packs; see IEC 62133-2 for wearable batteries.
- Transport test summary. The UN 38.3 test summary that carriers and forwarders check; see UN 38.3 for smart glasses.
- Substance declarations. Statements covering the substance restrictions in the regulation, alongside RoHS and REACH SVHC for the product.
- Label artwork. The battery information and collection symbol as they will appear on the box, manual or case.
These documents also feed the CE file for the glasses themselves, since EN 62368-1 safety testing looks at the battery and protection circuit. The radio side is covered in CE RED for smart glasses.
Design choices the regulation influences
Even where an obligation is not yet in force, it can be cheaper to plan for it at the design stage than to retrofit it. Three choices come up in smart glasses programs. The first is how the temple cell is held: glued, clipped or held in a carrier that a service centre can open. The second is the charging case: a case with its own battery brings its own labelling and documentation, while a cable-only charging design avoids a second battery. The third is information: a regulation that moves towards digital labelling makes it useful to plan where battery information will live, such as on the box, in the manual or behind a code on the packaging.
These choices also affect after-sales service and returns, since a repairable design can extend product life and reduce waste. They should be weighed together with weight, comfort and the water-resistance rating, which is usually IPX4 to IP54 across the category and tested per IEC 60529. The trade-offs in temple design are discussed in temple battery design.
Planning a launch in the EU
A practical sequence is to confirm the battery specification and documents with the partner plant, decide the producer role and registration route in each target country, prepare labels and manuals with the battery information, and review the design against the regulation's later obligations before the golden sample is frozen. The desk coordinates the plant documents and checks them against the product; the legal role and registration are the brand's to confirm. The wider map is in the certifications checklist, timing sits beside the ranges on MOQ and lead time, and the quote form asks for your EU countries so the documents can be requested early.