BATTERY COMPLIANCE

Around the world, the demand for batteries is dramatically increasing. Consequently, regulations impose stricter environmental rules of battery compliance. Along with performance and marking information, chemical restrictions have become a part of the requirements

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Battery Compliance in Europe

The Scope

Firstly, the applicable regulations in Europe are found in Regulation 2023/1542 on batteries and waste, also referred to as EU-Batt-R. The regulation encompasses all types of EU-marketed batteries, including:

portable,
industrial,
replaceable,
rechargeable or not,
SLI – Starting, Lighting, and Ignition,
LMT – Light Means of Transport.

Further, this regulation addresses a broad spectrum of requirements, from safety and sustainability to recycling and circularity.

Finally, any company seeking to import products into the 27 member states of the European Union must comply with these regulations as presented. Non-compliant producers and importers, including dealers and re-users, risk fines and shipping delays.

Battery Compliance Rules, in a Nutshell

This law restricts harmful substances in batteries, namely cadmium, lead, and mercury. But that’s not all. 2023/1542 also 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, with collection quotas. As a side note, 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.

Regulation 2023/1542 VS Directive 2006/66/EC

Regulation 2023/1542 is similar to the directive it replaces, namely 2006/66/EC. However, the emphasis leans toward substance restrictions and labeling requirements toward a circular economy. Examples include:

designing products so that users or professionals can easily remove and replace portable batteries;
holding restriction levels of cadmium and mercury stable
restricting the use of lead to 0.01% by weight
providing performance and durability information under certain conditions
issuing a CO2 footprint statement under certain conditions
extending labeling requirements for chemical composition
extending labeling requirements for collection and disposal
additional labeling requirements for product information, capacity, and non-rechargeability (if applicable).

Additionally, the EU-Batt-R is a regulation, not a directive. It means the EU member states must apply it as is, without national transpositions. Therefore, the implementation practices are the same between all member states.

Battery Labelling and Marking Requirements

According to the EU Regulation 2023/1542, several environmental labeling requirements apply to batteries, including the following:

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.
Beginning on August 18, 2025, all batteries should have a marking with the symbol for separate collection purposes. This symbol is similar to the one per the WEEE directive.
Starting from 18 August 2024, batteries must bear the CE marking. However, this marking does not include information regarding carbon footprint disclosure and recyclable materials. This information must be included in the marking at later dates, starting from 2026.
Starting on August 18, 2026, batteries must also 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

Specific Labelling Obligations

For SLI (exclusively used in vehicles, including cars, RVs, and trucks), LMT (mostly used in electric bikes and electric scooters), and rechargeable portable batteries (or secondary batteries), the label should contain definite capacity information.
Particularly, non-rechargeable portable batteries (or primary 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 Code

Starting on February 18th, 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, with manufacturer and CO2 footprint information, etc.
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.

On a side note, suppliers can print all the information above on batteries, their packaging, or the accompanying documents as a last resort.

Battery Compliance in China

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
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 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 States: NY Code – Section 27-0719: Battery management and disposal
California: AB-826 The Perchlorate Contamination Prevention Act, restricting the use of perchlorate. California Proposition 65 also applies to batteries.
Brazil: Batteries Conama Resolution No. 401
Turkey: Used batteries and accumulators control regulation No. 25569
Switzerland: Verordnung vom 9. Juni 1986 über umweltgefährdende Stoffe (Stoffverordnung, StoV) No. 814.013
Taiwan: Order 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 Regulations for Full Battery Compliance

Manufacturers must 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, like 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.

Are you ready to know more about battery compliance and secure supply chains? Contact Enviropass and talk with one of our experts.