No, it doesn't require a battery door, even for phones that don't meet the exception you mentioned.
Over a decade ago, I replaced a phone screen over a few hours, involving a couple dozen screws. During that, I had to remove the battery. (Replacing only the battery would have been easier.) I'm a layman, and all the screws were Phillips. That's sufficient to be replaceable.
The EU regulation we’re talking about essentially does, with an exception for high cycle batteries on waterproof phones
No, it doesn't require a battery door, even for phones that don't meet the exception you mentioned.
Over a decade ago, I replaced a phone screen over a few hours, involving a couple dozen screws. During that, I had to remove the battery. (Replacing only the battery would have been easier.) I'm a layman, and all the screws were Phillips. That's sufficient to be replaceable.