I think it may help to clarify that there are two Regulations which seem to have been muddled in the comments:
* Regulation 2023/1670 provides, inter alia, that smartphone manufacturers must make replacement batteries available to consumers, except where the 80%/1000 cycle criteria is met, in which case replacement batteries can be made only available to professional repairers. There is also a requirement for it being able to replace the battery but this does permit use of non-trivial tools under certain circumstances.
* Regulation 2023/1542 provides that portable batteries (not limited to smartphones) must be readily end-user replaceable if they meet certain criteria unless the strict waterproofing/medical industry criteria are met.
* Regulation 2023/1670 provides, inter alia, that smartphone manufacturers must make replacement batteries available to consumers, except where the 80%/1000 cycle criteria is met, in which case replacement batteries can be made only available to professional repairers. There is also a requirement for it being able to replace the battery but this does permit use of non-trivial tools under certain circumstances.
* Regulation 2023/1542 provides that portable batteries (not limited to smartphones) must be readily end-user replaceable if they meet certain criteria unless the strict waterproofing/medical industry criteria are met.