The applicable regulations in Europe are found in Regulation 2023/1542 on batteries and waste, also referred to as EU-Batt-R. The regulation encompasses all types of EU-marketed batteries, including:

portable,

industrial,

replaceable,

rechargeable or not,

SLI – Starting, Lighting, and Ignition,

LMT – Light Means of Transport.

Regulation 2023/1542 law restricts harmful substances in batteries, namely cadmium, lead, and mercury.  

Around the world, the demand for batteries is dramatically increasing. Consequently, chemical restrictions have become a part of the requirements.

Additionally, the EU-Batt-R is a regulation, not a directive. It means the EU member states must apply it as is, without national transpositions. Therefore, the implementation practices are the same between all member states.

Battery Labelling and Marking Requirements

According to the EU Regulation 2023/1542, several environmental labeling requirements apply to batteries, including the following:

Batteries that contain more than 0.002% cadmium or more than 0.0004% lead should bear a label with the appropriate chemical symbol: Cd or Pb.

Beginning on August 18, 2025, all batteries should have a marking with the symbol for separate collection purposes. This symbol is similar to the one per the WEEE directive.

Starting from 18 August 2024, batteries must bear the CE marking. However, this marking does not include information regarding carbon footprint disclosure and recyclable materials. This information must be included in the marking at later dates, starting from 2026. 

Starting on August 18, 2026, batteries must also bear a label with general information, including:

The manufacturer

The battery category

The date of manufacture (month and year)

The weight of the battery

The battery’s capacity

Any hazardous materials present in the battery other than mercury, cadmium, and lead

Any critical raw materials (e.g., cobalt, lithium, and natural graphite) present in the battery at a concentration of greater than 0.1% w/w

Battery Compliance in China

The applicable law in China is GB 24427-2021 Content limitation of Mercury, Cadmium, and Lead for Zinc Anode Primary Battery.

Substance Limits for Standard Batteries in China
Furthermore, the 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.

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

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