Within the Batteries Directive (2006/66/EC), lies Article 11. This article details the specific requirement that ‘manufacturers design appliances in such a way that waste batteries and accumulators can be readily removed’ and that ‘appliances into which batteries and accumulators are incorporated shall be accompanied by (i.e. supplied together with) instructions showing how they can be removed safely’.
How do you define ‘readily removed’?
In simple terms, users of the product must be able to remove the batteries from easily and safely. This applies to both consumers (someone replacing batteries in a remote control at home) or professional (employees at a waste sorting centre or a repair centre). Instructions provided with the product must clearly specify how to remove the batteries as well as who is best placed to do it (anyone or a specialist). The instructions should also specify the dangers of failing to follow the steps laid out. Additional battery legislation detail also exists for certain products where safety or ease is particularly important, such as toys. The removal batteries should be achievable during the lifetime of the product if the batteries would deplete before the product reaches end-of-life (i.e. a camera) or when the product reaches end-of-life.
Which products are covered by these requirements?
The requirements of Article 11 apply to electrical or electronic equipment (EEE), as defined in Article 3(11) of the Batteries Directive. Therefore non EEE products which contain batteries or accumulators do not need to meet the battery removal requirements BUT they must still comply with all collection requirements. Portable batteries and accumulators, including those incorporated into products, should be reported as specified in Article 10(3) of the Batteries Directive.
And which are exempt?
Products which require constant power supply for performance or safety are exempt from the directive. So too are products under certain medical or data integrity reasons which also require continuous power supply.
What freedom is there for the design of batteries within appliances?
All EEE containing batteries within scope must at a minimum comply with the requirements of Article 11. However, under Article 193 of the Treaty on the Functioning of the European Union, Member States are, if they wish, able to adopt stricter measures than those laid down in the Batteries Directive. Any additional measures must be aligned with other EU, provided they are compatible with the EU’s internal market rules, competition rules, etc. and the Commission is notified accordingly.
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