Battery Replacements and the Battle for Aftermarket Access

Regular readers will know that I often write about the increasing technological complexity of modern vehicles and the challenges this creates for the independent aftermarket. A new regulatory proposal has emerged in Brussels that perfectly illustrates why constant vigilance is needed to protect fair competition.
The issue centres on EV batteries – or REESS (Rechargeable Energy Storage Systems) as they're known in regulatory circles – and how they're replaced when they reach the end of their storage life.
The problem
EV batteries typically maintain their storage capability for six to seven years before degradation becomes significant. Extending this requires periodic charging under controlled conditions. But this is operationally difficult and economically challenging for manufacturers to manage across their inventories.
The practical solution is to limit the storage of old battery designs and replace a faulty battery with a new model. But there’s a snag: if that replacement battery is a newer specification than the original, it could compromise the vehicle's conformity with its original type approval, which is the certification that deemed it roadworthy in the first place.
The European Commission recognises this is a genuine problem that needs solving. Nobody benefits from perfectly serviceable vehicles becoming non-compliant due to a necessary battery replacement. So far, so reasonable.
Where it gets complicated
The Commission's proposed solution is to draft yet another Delegated Act. The challenge is in how they're proposing to implement it.
Under the current proposal:
- Only vehicle manufacturers could apply for part approval (not the parts manufacturers themselves)
- Installation would be restricted to workshops authorised by the vehicle manufacturer
- Approval could only come from the authority that granted the original vehicle type approval
For anyone familiar with aftermarket competition issues, alarm bells should be ringing. This approach would effectively create manufacturer-controlled monopolies over battery replacements. This would amount to exactly the kind of "captive parts" scenario that block exemption regulations were designed to prevent.
Part of a bigger picture
This isn't happening in isolation. It's part of a broader pattern we're seeing as vehicles become more technologically sophisticated. From secure access to on-board diagnostics (OBD) to spare parts coding systems, there's a recurring theme of manufacturers citing safety or security concerns to justify restricting independent access.
Sometimes these concerns are genuine. Sometimes they're convenient. The challenge for regulators – and for us as an industry – is distinguishing between the two and ensuring that solutions don't unnecessarily restrict competition.
The increasing evolution of vehicles into tech is inevitable and, in many ways, welcome. Advanced safety systems, improved efficiency and better performance are all positive developments. But this evolution cannot come at the cost of consumer choice and competitive markets.
Finding the right balance
To be clear we understand why the Commission is looking for a solution to the REESS issue. We're not opposing change for the sake of it. What we're asking for is an approach that solves the type approval challenge without simultaneously creating new barriers to independent service provision.
Through our work with industry partners like FIGIEFA, we've entered into constructive dialogue with the Commission to find that balance. Some of our concerns could potentially be addressed through ongoing amendments related to secure OBD access and spare part coding – issues we're already working through in other contexts.
Why this matters
If this precedent is set for batteries, what's next? Advanced Driver Assistance Systems (ADAS)? Euro 7 emissions components? Once the principle is established that safety-critical or emissions-related parts can only be fitted by manufacturer-authorised workshops, the door is open to extending that logic across an ever-widening range of components.
This is exactly the kind of creeping restriction that gradually erodes the independent aftermarket's ability to compete, not through a single dramatic change, but through a thousand small cuts.
Our commitment
LKQ Europe will continue to defend the rights of the independent aftermarket as vehicles evolve. We recognise that legitimate technical challenges need pragmatic solutions, but those solutions must preserve fair competition and consumer choice.
The automotive industry is changing faster than at any point in its history. As I've said before, that brings both challenges and opportunities. Our job is to ensure that the regulatory framework governing this transformation doesn’t lock independent businesses out of the market.
We'll keep you informed as discussions on REESS progress. As always, the strength of the independent aftermarket lies in our collective voice and our willingness to engage constructively with regulators to shape a future that works for everyone.