BATTERY COMPLIANCE

Around the world, laws regulate the concentrations of heavy metals (Cd, Hg, Pb) in cells or batteries. They impose binding limits that are stricter than the RoHS ones. These restrictions of chemicals in batteries are an essential part of battery compliance.

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Markets Regulating Batteries

Battery Compliance in Europe

The applicable regulation is directives 2006/66/EC and 2013/56/EU on batteries and accumulators and waste batteries and accumulators. These directives restrict harmful substances in batteries, namely cadmium, lead, and mercury.

Any company searching to import products into the 27 member states of the European Union must comply with the EU Battery Directive (2006/66/EC). Without compliance, suppliers risk receiving fines and encountering shipping barriers.

The directives demand:

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

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 Compliance in China

The applicable law 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.

Amendments to the 2009 regulations include:

revised substance concentration limits,
methods of testing, and
determination of 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. Determination is dependent on the results of parallel testing two parts from the same batch.

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

On Top of Battery Restrictions of Chemicals

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. It may also be necessary to subscribe to compliance schemes to arrange waste treatment, similarly to the WEEE regulations. This separate battery waste management is mandatory. It must be financed by producers in virtue of 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.

Ask Enviropass to perform compliance assessments on your behalf for the batteries you use, whether it is about labeling, technical documentation maintenance or simply following up with suppliers.

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