"Special tool" is not used in the actual regulation; the requirement is that replacement must be possible with basic tools, defined:
> (50) 'basic tools' means a screwdriver for slotted heads, a screwdriver for cross recess screws, a screwdriver for hexalobular recess heads [Torx], a hexagon socket key, a combination wrench, combination pliers, combination pliers for wire stripping and terminal crimping, half round nose pliers, diagonal cutters, multigrip pliers, locking pliers, a prying lever, tweezers, magnifying glass, a spudger and a pick;
(Excepted devices can require "commercially available tools" which is defined exactly as you'd expect.)
> A portable battery should be considered to be removable by the end-user when it can be removed with the use of commercially available tools and without requiring the use of specialised tools, unless they are provided free of charge […] to disassemble it.
> Commercially available tools are considered to be tools available on the market to all end-users without the need for them to provide evidence of any proprietary rights and that can be used with no restriction, except health and safety-related restrictions.
