Not necessarily: for smartphones, phones and tablets, Ecodesign Regulation 2023/1670 takes precedence over the Battery Regulation. A smartphone manufacturer may restrict replacement to a workshop if the battery retains 83% capacity after 500 cycles and 80% after 1,000 cycles, provided the appliance also withstands immersion (IP67); IP42 is sufficient for a tablet. The battery must remain available as a spare part for 7 years.
Read the source article: Battery passport 2027: removability rules and exceptions