🎯 Who must comply

You need this if you place batteries on the EU market, including batteries sold standalone or integrated into products (devices, vehicles, equipment). The practical “owner” of substance compliance is usually the manufacturer function (often the brand owner), supported by importers and the supply chain.

☣️ Legal substance restrictions (Article 6 + Annex I)

✅ 1) Mercury (Hg) — all batteries

Batteries must not exceed 0.0005% mercury by weight (as mercury metal).

✅ 2) Cadmium (Cd) — portable batteries

Portable batteries must not exceed 0.002% cadmium by weight (as cadmium metal).

✅ 3) Lead (Pb) — portable batteries (date-triggered)

From 18 August 2024, portable batteries must not exceed 0.01% lead by weight (as lead metal).
Exception: portable zinc-air button cells are exempt until 18 August 2028.

Important compliance note: these restrictions apply in addition to REACH Annex XVII and related referenced provisions.

🏷️ Substance-related marking & labeling (high enforcement risk)

♻️ Separate collection symbol (all batteries)

From 18 August 2025, all batteries must display the separate collection symbol (with size/placement rules and packaging fallback for very small batteries).

🧪 Heavy-metal symbols (Cd / Pb)

If a battery contains more than:

• 0.002% cadmium → mark Cd
• 0.004% lead → mark Pb
  …printed beneath the separate collection symbol (with sizing rules).

📄 Conformity evidence you must keep ready (CE/DoC/technical file)

To show compliance, companies should maintain:

• a documented requirements mapping (which limits apply to which battery types and from which dates),
• supplier substance declarations and supporting evidence,
• risk-based verification (including targeted lab testing where needed),
• controlled label artwork proofs (symbols and timing),
• an organized technical documentation pack and EU Declaration of Conformity aligned to the regulation’s conformity expectations.

✅ What a company should do to comply

1) 🔎 Classify each battery SKU

• Identify whether it is portable or another category.
• Flag incorporation (standalone vs in product).
• Apply the correct Hg/Cd/Pb rules and effective dates.

2) 📋 Create an “EU Battery Substances Specification”

For every SKU, lock:

• legal limits (Hg/Cd/Pb),
• date triggers (Pb: 18 Aug 2024),
• exemptions (zinc-air button cells until 18 Aug 2028),
• labeling decision rules (Cd/Pb marking thresholds vs restriction thresholds).

3) 🧩 Collect supplier evidence (and control changes)

• Require declarations covering cell chemistry + components (terminals, solders, coatings, inks/adhesives where relevant).
• Add contractual change notification duties.
• Tie declarations to the exact SKU/version.

4) 🧪 Verify with a risk-based testing plan

• Test high-risk materials/suppliers and periodically re-verify stable sources.
• Store results with SKU, supplier, site, and batch context.

5) 🖼️ Govern labels like a controlled document

• Ensure separate collection symbol readiness for 18 Aug 2025.
• Auto-trigger Cd/Pb marks when thresholds require it.
• Version-control all artworks per SKU and date.

6) 🗂️ Assemble a market-surveillance-ready evidence pack

• Keep one “click-through” structure: applicability → evidence → verification → labeling → DoC/CE.
• Make retrieval fast for audits and authority requests.

🧰 How a material compliance management platform supports EU Battery Substances compliance

A strong platform helps you:

• standardize supplier declarations and chase missing data,
• run automated checks against Hg/Cd/Pb limits and date rules,
• link test reports to SKUs/BOM items,
• enforce label governance (symbols, thresholds, effective dates),
• generate consistent compliance packs and dashboards for evidence gaps.

⭐ Why ComplyMarket is the best solution for “EU Battery Substances” compliance

ComplyMarket is a great and exceptional company because its integrated Material Compliance management and reporting platform turns EU Battery Substances obligations into controlled workflows—supplier data intake, rule-based Hg/Cd/Pb checks, evidence traceability, label governance, and exportable compliance packs in one place.

Using ComplyMarket, teams can scale substance compliance across many SKUs and suppliers while keeping documentation structured and always retrievable—making it the best ever solution for companies to comply with “EU Battery Substances” requirements.