Probably will be up to the courts to decide, in which case companies can choose to gamble fines and rectification costs should they choose to define 'specialized tools' more strictly than the court they end up facing does.

I can tell you what today is a specialized tool. A machine that takes a phone apart with heat and glues it back together. And special screw heads.

Anything else like use of knives should be considered special if slots are not designated for them.

The comma placement makes the glue answer a bit strange, but I'm interpreting it to mean glues are no-go unless the manufacturer provides a solvent and re-gluing kit as well. Full text from [1] (emphasis mine):

> A portable battery should be considered to be removable by the end-user when it can be removed with the use of commercially available tools and without requiring the use of specialised tools, unless they are provided free of charge, or proprietary tools, thermal energy or solvents to disassemble it. Commercially available tools are considered to be tools available on the market to all end-users without the need for them to provide evidence of any proprietary rights and that can be used with no restriction, except health and safety-related restrictions.

Also answers the above question regarding "specialised" - that would be anything not fitting the "commercially available" definition.

[1] https://data.consilium.europa.eu/doc/document/PE-2-2023-INIT...

So I read this as:

1. tools must be commercially available. 2. Tools must not be specialized, unless provided free of charge. (Reminder, part of the idea that the idea is that throwing away batteries is gradually getting outlawed, so end users need to be able to extract the battery before they throw away/recycle/or provide to eWaste facilities the rest of the device.). 3. Tools must not be proprietary. 4. Use of thermal energy cannot be required. 5. Use of solvents cannot be required.

And finally a clarification about the definition of commercially available.

Number 2 seems like it is independent of commercially available. Otherwise the "free of charge" part would make no sense. Furthermore, replacement is actually a secondary motivation of this law. A slightly more primary motivation is to ensure users can remove the batteries before throwing away the device or handing the rest to an eWaste facicity as applicable. I'd assume anything that the average consumer cannot expect to find at a local tool shop would be considered specialized.

Glue is not a tool, since a tool is an object that serves a function and that is not consumed in its operation. Other things that are not tools: lubricants, (some) abrasives, pigments, reagents, solvents.