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Around the world, laws regulate the concentrations of heavy metals (Cd, Hg, Pb) in cells or batteries. International regulations impose binding limits that are somewhat stricter than those found in RoHS. These chemical restrictions are an essential part of battery compliance.

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Battery Directive Compliance

Battery Compliance in Europe

European Union RoHS Flag

Firstly, the applicable regulations in Europe are found in Directive 2023/1542 on batteries and waste. This directive restricts harmful substances in batteries, namely cadmium, lead, and mercury.

In other words, any company seeking to import products into the 27 member states of the European Union must comply with this directive as presented. Non-compliant suppliers risk fines and shipping delays.

In fact, (EU) 2023/1542 provides regulations or guidelines concerning several issues, including:

  • proper labeling of battery products;
  • financing collection and recycling programs; and
  • raising public awareness with campaigns encouraging correct waste disposal.


This directive is similar to the regulation it replaced, namely the EU Battery Directive 2006/66/EC. Emphasis leans toward substance restrictions and labeling requirements. Examples include:

  • holding restriction levels of cadmium and mercury stable
  • restricting the use of lead to 0.01% by weight
  • extending labeling requirements for chemical composition
  • extending labeling requirements for collection and disposal
  • additional labeling requirements for product info, capacity, and non-rechargeability (if applicable)


Importantly, producers cannot charge for a separate collection of disposed battery products.

Additionally, the REACH regulation, with its list of Substances of Very High Concern and its restrictions under Annex XVII is another applicable EU obligation to batteries.

Battery Labelling and Marking Requirements

According to the EU Directive 2023/1542, several environmental labeling requirements are applicable to batteries, including the following:

  1. Batteries that contain more than 0.002% cadmium or more than 0.0004% lead should bear a label with the appropriate chemical symbol: Cd or Pb.
  2. Beginning on August 18, 2025, all batteries should have a marking with the symbol for separate collection purposes. This symbol is simiral to the one per the WEEE directive.
  3. Starting on August 18, 2026,
  • Batteries must bear a label with general information, including:
    • The manufacturer
    • The battery category
    • The date of manufacture (month and year)
    • The weight of the battery
    • The battery’s capacity
    • Any hazardous materials present in the battery, other than mercury, cadmium, and lead
    • Any critical raw materials (e.g., cobalt, lithium, and natural graphite) present in the battery at a concentration of greater than 0.1% w/w
  • For SLI – Starting, Lighting, and Ignition batteries (exclusively used in vehicles, including cars, RVs, and trucks), LMT – light means of transport batteries (mostly used in electric bikes and electric scooters), and rechargeable portable batteries, the label should contain definite capacity information.
  • Particularly, non-rechargeable portable batteries must bear a label including a “non-rechargeable” tag and information on the minimum average lifespan of the battery when used in specific applications.
QR codes Product Environmental Information

4. Starting on February 18. 2027, all batteries shall contain a label with a QR code providing access to the following:

  • For LMT batteries, industrial batteries with a capacity exceeding 2kWh, and batteries for electric vehicles: The battery digital product passport.
  • For other batteries: The applicable information, the declaration of conformity, the report, and the information on waste battery management and prevention.
  • For SLI batteries: The concentration of cobalt, lead, lithium, or nickel recovered from waste and found in active materials in the battery.


Note that all the information explained above can be printed on batteries, their packaging, or the accompanying documents.

Battery Compliance in China

China RoHS Flag

Secondly, the applicable law in China is GB 24427-2021 Content limitation of Mercury, Cadmium, and Lead for Zinc Anode Primary Battery.

As of April 30th, 2021, the State Administration for Market Regulation (SAMR), in collaboration with the Standardization Administration of the P.R.C (SAC) established GB 24427-2021. This regulation repeals both GB 24427-2009 Limitation of mercury, cadmium, and lead contents for alkaline and non-alkaline zinc manganese dioxide batteries and GB 24428-2009 Limitation of mercury content for zinc silver-oxide, zinc oxygen, and zinc manganese dioxide button batteries.

Specifically, amendments to the 2009 regulations include:

  • revised substance concentration limits,
  • methods of testing, and
  • determining compliance with requirements for cadmium, lead, and mercury in the standard:
    • zinc-manganese dioxide batteries,
    • zinc silver oxide batteries, and
    • zinc-air batteries.

Substance Limits for Standard Batteries in China

Battery Type

Cadmium (ppm)

Lead (ppm)

Mercury (ppm)

Alkaline zinc-air button

< 40

< 500

< 5

Alkaline zinc manganese dioxide

< 10

< 40

< 1

Alkaline zinc manganese dioxide button cells

< 20

< 40

< 5

Non-alkaline zinc manganese dioxide

< 100

< 1000

< 1

Zinc silver oxide button

< 40

< 200

< 5

Furthermore, the new Chinese testing standard for mercury, cadmium, and lead in batteries is GB/T 20155. Analysts employ parallel testing, and two parts from a given batch produce the results for this determination.

Other Markets with Battery Compliance Obligations

  • United StatesNY Code – Section 27-0719: Battery management and disposal
  • California: AB-826 The Perchlorate Contamination Prevention Act, restricting the use of perchlorateCalifornia Proposition 65 also applies to batteries.
  • BrazilBatteries Conama Resolution No. 401
  • TurkeyUsed batteries and accumulators control regulation No. 25569
  • Switzerland: Verordnung vom 9. Juni 1986 über umweltgefährdende Stoffe (Stoffverordnung, StoV) No. 814.013
  • TaiwanOrder Huan-Shu-Fei-Tzu – Restriction on the Manufacture, Import, and the Sale of Dry Cell Batteries
  • Georgia: Resolution №324 of May 25th, 2020, On the approval of the technical regulation on waste management of batteries and accumulators, aligned with the EU Directive 2006/66/EC

Other (Non-Chemical) Restrictions for Batteries

  • Manufacturers must design their devices so that the batteries are easily replaceable.
  • They must also provide the end-user with instructions on the location and safe removal of batteries.
  • Additionally, it is mandatory to register the annual quantities of batteries placed on the market. You may also need to subscribe to waste treatment compliance schemes, as with WEEE regulations. Such separate battery waste management is mandatory, and producers must finance it under the extended producer responsibility (EPR).
  • Finally, producers and importers may also have to appoint an authorized representative (AR). The good news is that, unlike WEEE, only one AR is necessary to cover the entire EU.

As a side note, regulations apply to other products, like electrical and electronic components or packaging.

Are you ready to know more about heavy metals in batteries? Contact Enviropass and talk with one of our experts.