FAQ
A frequently asked question (FAQ) is just that and on this page we have tried to provide answers, based on the most up to date information we have at the time of writing, to some of the most frequently asked Batteries questions that we receive.
If you can’t find the answer to your question here you can always contact us via the enquiries page.
Please choose from one of the following FAQ categories:
Are there any exemptions to the regulations?
There are some exemptions, in general terms the Regulations will not apply to either:
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Batteries used in equipment connected with the protection of an EU country's essential security interests, such as arms, munitions and war material, and intended for specifically military purposes
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Batteries used in equipment designed to be sent into space
What is a battery?
A battery or accumulator is considered to be any source of electrical energy generated by direct conversion of chemical energy and consisting of one or more primary battery cells (non-rechargeable or disposable batteries) or consisting of one or more secondary battery cells (accumulators or rechargeable batteries).
What is a battery pack?
A battery pack is any set of batteries that are connected together or encapsulated within an outer casing so as to form a complete unit that the end-user is not intended to split up or open.
What is a button cell?
A button cell is any small round portable battery the diameter of which is greater than the height and which is used for special purposes such as hearing aids, watches, small portable equipment and back-up power.
What is a portable battery?
A portable battery is any battery or battery pack which is:
- Sealed
- Can be hand carried by an average natural person without difficulty
- Neither an automotive battery or accumulator nor an industrial battery
Examples of a portable battery include:
What is an automotive battery?
An automotive battery is a battery of any size or weight that is used for the starting or ignition of the engine of a road going vehicle, such as a motorcycle, car, van, truck, bus or coach or for providing power for any lighting used by such a vehicle.
This includes such batteries used in vehicles that are of a road-going nature but not actually used on public roads, such as a racing car or tractor. Any other batteries used in vehicles, such as the battery in a key fob, are not automotive batteries. Batteries providing the power to drive electric vehicles are classified as industrial batteries.
What is an industrial battery?
An industrial battery is a battery or battery pack of any size or weight which is:
Do I have to label all the individual cells contained within a battery pack?
As it is not intended for end-users to split these packs open, the individual cells in a battery pack do not need to be marked with the crossed out wheeled bin or chemical symbols, but the battery pack itself does need to be marked.
Do batteries and accumulators incorporated into appliances, not visible to or removable by the consumer, still need to be labelled?
They need to be marked with the appropriate chemical symbols as they provide vital information to those dealing with end of life treatment, but not the crossed out wheeled bin symbol as these batteries are neither visible to nor removable by the consumer.
How do I label small batteries with the crossed out wheeled bin or chemical symbol if sold separately or if they are sold incorporated in an appliance?
If the crossed out wheeled bin symbol would be smaller than 0.5 x 0.5 centimetres when printed on a battery that is sold separately, it should instead be printed on the packaging of the battery.
If the crossed out wheeled bin symbol would be smaller than 0.5 x 0.5 centimetres when printed on a battery that is sold incorporated into an appliance, a crossed out wheeled bin symbol measuring at least 1 x 1 centimetre should instead be printed on the packaging of the appliance.
In both cases the appropriate chemical symbol would need to be printed on the packaging below the crossed out wheeled bin symbol as per the Regulations.
What does readily removable mean?
Readily removable means that consumers or professionals e.g. appliance service centres, watch menders, camera shops, and waste management facilities etc. should be able to remove batteries from appliances. The product must be accompanied with instructions explaining how the batteries can be readily and safely removed. They should also specify who, in the view of the manufacturer, is the best person to safely remove the battery.
Do I need to include manuals or instructions with my appliances or can I supply them online only?
The Directive and the Regulations specifically state that the appliance must be "accompanied by instructions showing how the battery can be removed safely."
Can I place a product on the market with a battery that can only be removed by a professional, or at the end of life at a waste facility?
Only within the limits explained in the government guidance notes. For example, a back-up battery for a clock in an electricity meter that is intended to last the full operational life-span of the product, does not necessarily have to be readily removable by the consumer. However, a battery in a normal household clock should be accessible by the consumer to remove or replace, unless the manufacturer can demonstrate that it would normally out-last the life of the clock itself. The requirement for easy removability is intended both to encourage recycling and to discourage the production of short life-span products that need to be thrown away, merely because the battery has expired.
When should waste batteries and accumulators be removable from appliances?
Waste batteries should be removable from the appliances during the lifetime of the appliance if the batteries normally have a shorter lifetime than the appliance. Or alternatively, at the latest, at the end of the life of the appliance, as applicable.
What is placing on the market?
The term placing on the market is the initial action of making a product available for the first time on the Community market, with a view to distribution or use in the Community. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution or use on the Community market and applies to each individual product, and not a type, series or line of product.
Can I export non-compliant goods to countries outside of the EU?
The Directive does not apply to exported products placed on markets outside of the EU, only to products imported from outside of the EU to the EU market.
Are prototypes used at exhibitions and trade fairs considered to be placed on the market?
A product is not considered to be placed on the market when it is displayed at trade fairs, exhibitions or demonstrations. However, it must be clearly marked as not being placed on the market and must not be put into use. As such, any non-compliant product is for display purposes only. Prototypes for experimentation may be used providing they are not made available on the EU market.
Are ‘own use’ products considered to be placed on the market?
Products imported for own use are considered placed on the market, even when imported from another branch of the same organisation outside the EU and therefore must comply. However, products built for own use are generally not considered as being placed on the market and therefore do not have to comply.
Are products stored in warehouses considered to be placed on the market?
Placing on the market is considered not to take place where a product is in the stocks of the manufacturer. However, imports of finished products that have cleared customs and are being held by the producer without any further process required are considered to have been placed on the market.
