[daemonologist]

"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.)

https://eur-lex.europa.eu/eli/reg/2023/1670/oj