"Products placed on the market [...] in applications that the end-user is not intended to split up or open [...] should be subject to requirements applicable to batteries."
This sounds to me like as long as they have a recycling program for cellphones, the entire phone can be considered the "battery" and no user replaceablilty is necessary.
>Products placed on the market as battery packs, which are batteries or groups of cells that
are connected or encapsulated within an outer casing to form a complete unit ready for use
by end-users or in applications that the end-user is not intended to split up or open and
which conform to the definition of batteries, or battery cells that conform to the definition
of batteries, should be subject to requirements applicable to batteries.
I don't think phones can be considered being placed on the market as battery packs
"Products placed on the market [...] in applications that the end-user is not intended to split up or open [...] should be subject to requirements applicable to batteries."
This sounds to me like as long as they have a recycling program for cellphones, the entire phone can be considered the "battery" and no user replaceablilty is necessary.