this post was submitted on 20 Jun 2023
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Is this (article 11 on page 55) the approved text? It seems kind of vague on what constitutes "readily removable and replaceable."
No, this is the adopted text. Its basically an update of the text you linked, which is the regulation from 2020. The relevant part you want might be (38) and (39):
Good post, thanks.
It's contradictory, what about commercially available specialized tools? Who defines what's specialized and not?
I mean...you can be pedantic about it, but to me this reads fairly clearly as "If it can't be removed with a screwdriver, it's not allowed."
The evil is always in details, thats why with their Incandescent light bulb ban, these are now sold as heating devices/lamps, so much for their bans/rules. That's why I pointed out commercially available tools can be at same time specialized tools, they should rather mention something like it must be tools owned by 50% households according stats and do simple survey about screwdrivers.
I'm going to be honest, I think that this is a case where companies will always dodge the rules unless the consequences are so severe they're unwilling to risk it. Something like forced downsizing, or a fine proportional to annual revenue. That would make companies significantly more hesitant to try and tread the line.