With all due respect, I can buy a kit on iFixit for $55 for an iPhone 16 pro max, including the battery. I’ve replaced my iPhone battery before, aside from the glue being a bit sticky so needing a heat gun it isn’t that difficult.
Vendor or even model specific tools plus fighting with glue is not that complicated for someone willing to dedicate the effort, but it won't help recycling economy.
Which is fine - but the law is the law and will look at what Apple (et al) provide and document.
(Thought Apple's $99 to do the repair themselves isn't terribly bad all things considered; and likely part of their attempt to forestall complaints and litigations).
Even with a good battery, bugs/features on the latest iOS can make iPhone 15 Pro Max battery last terribly, terribly short.
Part of the new requirement should be they can't kill battery lifespan in 2-year old phones through software updates, either.
Because even "replaceable battery" doesn't fix that serious problem!
I've replaced a battery in my 2019 Xiaomi phone for $5 (the costs of the battery), using basic tools - albeit the back was already ungluing itself, making that part easier. At 10x the price, it's hard not to call it a massive markup.
And you can do it for much less if you want. I've replaced phone batteries with 6 dollars worth of tools and a hairdryer. You can buy glue or sticky gaskets for next to nothing as well if you care about waterproofing.
> so needing a heat gun it isn’t that difficult.
Heat gun? This isn't the type of consumer-friendly battery replacement which the EU is looking for.