EU-bound programmes: decide the service route before the design is fixed
The European Commission's battery removability and replaceability guidance, published 14 July 2026, explains that Article 11 of Regulation (EU) 2023/1542 applies from 18 February 2027. Products incorporating portable batteries can face end-user removal, replacement and spare-availability obligations. This is non-binding Commission guidance: applicability depends on the product and battery classification, relevant derogations and other product requirements. Check that scope for the exact design; a detachable or rechargeable format alone does not establish compliance. See the Commission guidance PDF, introduction and sections 2–5.
For programme planning, give the following decisions an owner before approving tooling or packaging. This is a suggested purchasing workflow, not a complete legal checklist or a promise about any TUODI model.
| Decision | What to settle | Evidence and programme owner |
|---|---|---|
| Scope and service user | Which requirements apply to this product and battery, and who must be able to perform each service task? | Product/compliance lead records the classification and any relied-on exception before design approval. |
| Battery removal | Distinguish taking down the light for charging from removing its battery. Check access, tools and the installed furniture or mounting arrangement. | Engineering demonstrates the permitted removal sequence on the selected sample and records any damage or access problem. |
| Battery replacement | Define a compatible replacement and verify fit, connection and operation after refitting. | Engineering and quality retain the replacement specification and observed sample result; do not approve from a connector photograph alone. |
| Spare identification and instructions | Match the product reference, battery reference and safe replacement instructions so the user can identify the intended spare. | Product and service teams check labels and instructions together and keep a controlled copy for support. |
| Availability and programme ownership | Confirm applicable spare obligations and agree who maintains supply, ordering access and compatibility when a component changes. | Procurement and the responsible programme lead record the supplier commitment, change-review trigger and service contact. A sample swap does not establish future supply. |
Four sensor-lighting architectures to compare
| Architecture | Strong fit | Main lifecycle risk | Sample question |
|---|---|---|---|
| Sealed rechargeable battery | Low-duty consumer products where compactness and opening price dominate. | The whole unit may become the replacement item when the cell degrades or the charging path fails. | Can the battery or unit be replaced, and what happens to the mounting hardware? |
| Removable light bar | Wardrobes, shelves and cabinets where magnetic or clipped mounting is easy to reach. | Repeated removal can disturb alignment, clips, adhesive plates or charging routines. | Can a normal user remove, charge and reinstall it without loosening the mount? |
| Replaceable battery module | Serviced furniture, rental units and installations where the bar should remain mounted. | Future spare compatibility, connector wear and battery-module availability become programme requirements. | Can the module be changed safely, and how is the exact replacement identified? |
| Wired low voltage | High-use hospitality, display, fitted-furniture and long-life projects with cable access. | Driver placement, voltage drop, cable routing and installation access can move cost from product to site. | Can the driver and connection points be reached without dismantling the installation? |
What “serviceable” means in a real installation
Serviceability is a chain, not one feature. A replaceable battery is not useful if the connector is hidden behind a fixed panel. A removable bar is not convenient if the user needs a ladder every week. A wired system is not maintainable if the driver is sealed above a finished ceiling.
- Access: who can reach the light, battery, driver and connector after installation?
- Identification: can maintenance staff identify the correct spare without opening the product?
- Replacement: does servicing disturb furniture, paint, adhesive plates or wiring?
- Continuity: will the same spare, connector and mounting interface remain available for the programme?
- Instructions: can a normal user complete the permitted task without creating a safety or warranty problem?
Choose by application, not by the newest feature
Protect flat-pack simplicity
A removable magnetic bar avoids wiring and keeps installation simple. Check charging access, mounting retention and whether the replacement unit will fit the same plates.
Reduce maintenance touches
Multiply charging and replacement work by the number of rooms. A removable module or wired system can be worth more than a lower opening unit price.
Separate the fixture from the wear item
Where staff maintain many units, standardised spares and visible model identification reduce the chance of incompatible replacements.
Define the end-of-life story
Packaging, instructions, warranty handling and spare availability should match the chosen architecture—not be written after the product is already fixed.
What to test on the sample
Do not test only brightness and sensor range. Run the complete maintenance action with the people who will actually perform it.
| Test | What to record |
|---|---|
| Removal and refit | Time, tools, force, alignment and whether clips, magnets or adhesive plates move. |
| Charging access | Cable clearance, indicator visibility, heat and whether the product can be used while charging. |
| Battery or spare swap | Connector access, polarity protection, labelling, safe handling and the exact replacement code. |
| Low-battery behaviour | Warning, dimming, sensor stability and whether settings are retained after power loss. |
| Repeated handling | Wear after realistic removal, charging and reconnection cycles. |
| Installed sensing | Trigger and shut-off behaviour with the real door, panel, mounting height and surrounding material. |
A worked comparison of the two published configurations
The Detachable-Battery Sensor Light (TDL-6111) lets the battery card be charged while the magnetic light section stays mounted. That shared architecture does not make the two published configurations interchangeable. Use the exact configuration reference, rather than a family average, when deciding whether the installed location can be serviced.
| Configuration reference | Configured span and composition | Light section dimensions | Power and output | Battery-card fields |
|---|---|---|---|---|
TDL-6111 · 35 cm configured spantdl-6111-35cm@3 | 35 cm configured span 25 cm light section plus 10 cm battery card | 250 × 38 × 9 mm | Power: 1.3 W Tolerance: ±10% Output: 136 lm | Battery capacity: — LED count: — Hold time: — Separate replacement-card supply: — |
TDL-6111 · 54 cm configured spantdl-6111-54cm@3 | 54 cm configured span 40 cm light section plus 14 cm battery card | 400 × 38 × 9 mm | Power: 2 W Tolerance: ±10% Output: 208 lm | Battery capacity: 3000 mAh LED count: 146 LEDs Hold time: 15 s Separate replacement-card supply: — |
Values shown are factory specifications for each configured span; your quotation states the values for the build you select. Fields marked — : To be confirmed on your quotation.
Before approving a drawing or purchase order, use the selected reference to settle installed clearance for removing the battery card, separate replacement-card availability and compatibility, and whether the published document applies to the selected build and destination. Neither record promises DIY servicing, an installation load rating, a spare period or compatibility with an unlisted accessory.
Questions to put in the RFQ
- Who will charge or service the installed product, and how often?
- Which part is intended to be replaced: the whole light, the light bar, the battery module or the driver?
- What tools and access are required after installation?
- How is the correct spare identified, ordered and kept compatible?
- Which change to battery, connector, firmware or housing would trigger a new sample or document review?