I also don't see anything supporting this interpretation in the actual regulation - quite to the contrary. It repeatedly refers to all batteries, and says nothing of any class of devices that are exempt.
> new regulatory framework for batteries will consider rules on recycled content and
measures to improve the collection and recycling rates of all batteries
> It is necessary to create a harmonised regulatory framework for
dealing with the entire life cycle of batteries that are placed on the market in the Union.
> It is also necessary to update Union law on the management of waste batteries and to take
measures to protect the environment and human health by preventing or reducing the
adverse impacts of the generation and management of waste,
https://data.consilium.europa.eu/doc/document/PE-2-2023-INIT...