Environmental Assessment


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

Markets Regulating Batteries

Battery Compliance in Europe

European Union RoHS Flag

Firstly, the applicable regulations in Europe are directives 2006/66/EC and 2013/56/EU on batteries, accumulators, and waste. These directives restrict harmful substances in batteries, namely cadmium, lead, and mercury.

In other words, 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). Non-compliant suppliers risk fines and shipping delays.

The directives demand:

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

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.