Batteries: Compliance assessment

Is your equipment compliant with the Batteries Directive?

The new Batteries Directive, which came into force in EU Member States from 20 November 2013, applies to all types of batteries and specifically includes batteries which are incorporated into electrical equipment. thinkstep can assess legal exposure to the Batteries Directive for sales of your equipment in Europe and provide a detailed Compliance Action Plan for your company.

Does your company need to register as a Batteries producer in EU Member States?

The Batteries Directive applies to all types of batteries and specifically includes batteries incorporated into appliances, apart from batteries contained in military and space equipment. The Directive defines three categories of battery, and places different requirements on battery producers in each category:

  • Portable battery = battery or battery pack that is sealed, hand carried and not an industrial or automotive battery
  • Industrial battery = battery designed exclusively for industrial or professional uses
  • Automotive battery = battery used for automotive starter, lighting or ignition power

A 'battery producer' is defined as the first person to put batteries on the market in an EU Member State, including batteries incorporated in appliances

Many Member States have partially or fully implemented new Batteries Regulations and established timescales for companies to register as a battery producer. Some Member States, however, are late in introducing these new Regulations and in many Member States the registration process has yet to be finalized.

How thinkstep can help

We can assess legal exposure to the Batteries Directive for sales of your equipment in Europe. The findings are summarized in a detailed Compliance Action Plan which is tailored to the needs of your company. Our quarterly update service will keep you up to date on latest developments as the regulations are finalized and implemented in Member States.

Compliance responsibilities

At the outset, we determine who is responsible for compliance by carrying out:

  • An assessment of your sales arrangements in Europe to determine compliance responsibilities for your equipment.
  • An assessment of the batteries in your equipment against the Battery Directive categories (this assessment is critical as it will in turn determine the compliance options available you);

Substance restrictions

The Batteries Directive contains a number of substance restrictions. We assess the impact of these substance restrictions on the batteries you are currently using in your equipment.

Labelling requirements

There are labelling requirements for batteries and battery packs including:

  • the crossed-out wheelie bin symbol;
  • battery capacity;
  • chemical symbols.


We advise how these labeling requirements apply to your products.

Design for the removability

Article 11 of the Batteries Directive requires manufacturers to "design equipment in such a way that waste batteries can be readily removed". The Directive also requires the manufacturer to provide instructions with the equipment showing how waste batteries can be removed safely. thinkstep has worked with the European Commission and UK Government on this issue and has extensive experience of how the removability requirement should be interpreted in practice for different types of equipment. We also advise on suitable wording to include in your instructions for use.

Registration as a Battery Producer in EU Member States

The registration process and deadlines are different in each Member State. thinkstep cuts through the confusion and helps you to register in all Member States where you have the obligation as the battery producer.

Collection, recycling and reporting arrangements

In practice, if your equipment includes portable batteries then there is no option except to join approved producer compliance schemes to provide collection, recycling and reporting arrangements in relevant Member States. In some countries, if your equipment includes industrial batteries then establishing your own collection, recycling and reporting arrangements can be a more practical and cost-effective option. thinkstep analyses the options for you, provides a comparison of the different approved compliance schemes which are available in Member States and can assist you with registering as a batteries producer in EU Member States and membership to a batteries compliance scheme if required by the Batteries Regulations in that particular country.

Compliance Action Plan

We compile our analysis into a comprehensive Compliance Action Plan which is tailored to the needs of your company. This step-by-step approach will enable you to meet all compliance requirements in EU Member States.

Contact us

Howard Stimpson
Manager of WEEE, RoHS and Eco-Design

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