Quote from https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C...

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Article 11 of Regulation (EU) 2023/1542 states that a battery shall be considered readily removable by the end-user where it can be removed from a product with the use of commercially available tools, without requiring the use of specialised tools, unless provided free of charge with the product, proprietary tools, thermal energy, or solvents to disassemble the product.

Guidance on tool types can be drawn from standard EN 45554:2020e (2). In the context of the assessment of a product’s ability to be repaired, reused and upgraded, this standard uses the following classification groups: (i) basic tools (including those provided with the product as a spare part) or no tools; (ii) product-group specific tools; (iii) commercially available tools; and (iv) proprietary tools.

The concept of commercially available tools mentioned in Article 11 comprises the categories of basic tools or no tools and of commercially available tools as per EN 45554:2020e.

The concept of specialised tools laid down in the Regulation refers to product-group specific tools that are not available for purchase by the general public but are not protected by patents either. Article 11 requires that any such specialised tool that might be necessary to have a portable battery removed and replaced is provided free of charge with the product into which the battery is incorporated.

As per EN 45554:2020e, proprietary tools refer to tools not available for purchase by the general public, or for which any applicable patent are not available for license under fair, reasonable and non-discriminatory terms. Such tools should not be needed to remove portable batteries

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(I fully expect literally no one on HN to spend even a second looking for and reading the relevant texts, and complain about the law being vague or impossible to implement or something)