Are Batteries and Packaging Materials Within the Scope of RoHS?

Little Pro on 2018-03-17

People often ask if batteries and packaging materials are also within the scope of RoHS or not since they are closely related to electrical and electronic products. If they were out of scope, are there any hazardous substance restriction requirements for batteries and packaging materials? In this article, we will try to give you a quick answer for different RoHS regulations (i.e, EU, China, US, Korea).


Jurisdiction Within the Scope of RoHS?

No. Batteries and accumulators are regulated by separate Batteries Directive (DIRECTIVE 2006/66/EC). However, hazardous substance restriction requirement is more stringent than RoHS (see below):

  • all batteries or accumulators, whether or not incorporated into appliances: less than 0.0005 % of mercury by weight; and
  • portable batteries or accumulators, including those incorporated into appliances: less than 0.002 % of cadmium by weight

Exemptions:portable batteries or accumulators used in (a) emergency and alarm systems, including emergency lighting; (b) medical equipment;


US/California RoHS

No. Batteries are out of scope.


China RoHS 2

Yes. Only batteries to be used in China RoHS excluded electrical and electronic products are out of scope.

Different types of batteries also need to comply with compulsory national standard GB 24427-2009 Limitation of mercury, cadmium and lead contents for alkaline and non-alkaline zincmanganese dioxide batteries and GB 31241-2014 Lithium ion cells and batteries used in portable electronic equipments-Safety requirements.


Korea RoHS

No. Batteries are covered in Quality Management and Safety Control of Industrial Products Act.


Taiwan RoHS

No. Batteries are out of scope.


Packaging Materials

Usually packaging materials are out the scope of RoHS since there are separate regulations or standards for packaging materials. This applies to EU RoHS 2, China RoHS 2 and Korea RoHS. More info can be found below.

More About RoHS

Country/region Summary & Reference
  • China RoHS 2.0: The Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (Being drafted).
  • Restricts the same 6 hazardous substances as EU RoHS 2.0;
  • Additional RoHS labelling requirements set by SJ/T 11364-2014;
  • More info about China RoHS 2.0.
  • Japan RoHS: JIS C 0950 The marking for presence of the specific chemical substances for electrical and electronic equipment;
  • Applicable to 7 types of electrical and electronic products;
  • Mandatory disclosure and labeling if the content of 6 hazardous substances exceeds certain limits;
  • Read more about Japan RoHS
  • Korea RoHS: The Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles (2007);
  • Korea's version of the RoHS, WEE and ELV directives;
  • Restricts the same 6 hazardous substances as EU RoHS 2.0;
  • Read more about Korea RoHS
  • Taiwan RoHS:CNS 15663 Guidance to reduction of the restricted chemical substances in electrical and electronic equipment;
  • Voluntary national standard restricting the same 6 hazardous substances;
  • Sets its own hazardous substance marking requirement.
  • More info about Taiwan RoHS
  • No federal RoHS-style legislation;
  • California's Electronic Waste Recycling Act of 2003 (EWRA) prohibits the sale of some electronic devices after January 1, 2007, that are prohibited from being sold under the EU RoHS directive;
  • The substances restricted are "certain heavy metals," specifically lead, mercury, cadmium and hexavalent chromium;
  • Reference

Reference & Resources

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