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.

I’m glad they got specific. I wonder where Apple’s self-service battery replacement program falls under this? AFAIK it’s not free. They charge a fee to rent the specialized tools, which are also proprietary.

This gives Apple a few choices:

Make the tools commercially available, but at an astronomical price in typical Apple fashion

Make the tools commercially available at a normal consumer price (unlikely)

Make the self-service battery replacement program free (most likely, but will require a significant revision to the tools used since they are industrial-grade)