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I don't know if the changes coming into affect today have something different about replaceable batteries, but the 2027 replaceable battery requirement has this as the exemption:
Article 11 of Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries
The only thing there Apple could even pretend is "washable or rinsable", and I'd be shocked* if they could get away with that.
*not that shocked