Critical Links

North American companies exporting batteries into Europe need to be aware not only of substance restrictions, but also a raft of labelling and information requirements.

In addition to mercury, which has been restricted for some time (maximum 0.0005% by weight of the battery, other than button cells where a maximum of 2% by weight is permitted), cadmium is now also restricted. A maximum of 0.002% by weight of the battery is permitted, but with three exemptions. These are emergency and alarm systems, including lighting, medical equipment, and cordless power tools, although the latter will be reviewed by September 2010.

Labelling requirements include the crossed out wheelie bin and the “Hg” and “Cd” symbol below this, where the battery contains more than the permitted values. While lead is not restricted, “Pb” needs to be shown when the battery contains more than 0.004% by weight. From September 2009, portable and automotive batteries are required to indicate the capacity of the battery.

Other information that is required includes the potential effect of substances used in batteries on both health and the environment, an explanation of the symbols used on the battery, a note requesting that batteries are not disposed of with other waste, and details of collection and recycling schemes.

Finally, and potentially affecting the design of electrical equipment, the battery must be “readily” or easily removed, although how is not defined under the legislation. Clearly this requirement is intended to ensure that users are able to remove batteries by opening a cover by hand or after the removal of one, or a small number of screws. Lengthy dismantling that takes considerable time would not be permitted.

On May 5, the UK introduced new regulations that had significant impact on the “Producer,” although they will clearly be looking for help from the battery manufacturer on many of the requirements mentioned above. Anyone who places portable batteries or accumulators (re-chargeable) -- or products containing portable batteries or accumulators -- onto the UK market for the first time, will be classified as a battery producer. This includes retailers and importers, as well as wholesalers who import portable batteries or accumulators to place on the UK market.

Producers that place more than 1 ton of portable batteries into the UK market each year will have to pay for the collection, treatment, recycling, and disposal of waste batteries, in proportion to their market share. They will do this by joining a Battery Compliance Scheme, which will arrange for the collection, treatment and recycling of waste batteries for them.

The aim of the directive is to limit the number of batteries that still end up in landfill sites.

About the author
As director of legislation and environmental affairs, Gary Nevison is Newark's and Farnell's spokesperson and customer interface on legislation that affects the electronics industry, such as the ROHS (all variations around the world), REACH, EuP, and WEEE directives. For more on Gary, click here.