Notes on Environmental Regulations

Certificate of Conformity to Battery Directive

We hereby certify that our alkaline batteries delivered to you conform to Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators (referred to as the “Battery Directive”). According to the Directive, the following restricted substances andlabeling requirements are set down and our batteries conform to these requirements. In addition, easy removal of batteries from the applications is also set down in the Directive, therefore your taking into consideration this requirement in the design stage of your application is appreciated.
  1. Restricted substances (Article 4)
    Batteries containing the following substances with more than the designated content by weight are prohibited to be placed on EU market:
    Mercury: 5ppm
    Cadmium: 20ppm
  2. Labeling (Article 21)
    A mark meaning separate waste collection should be placed on all batteries and accumulators in EU member states. We put marks on the body of the battery for cylindrical and prismatic batteries, or on the packaging for small batteries such as cointype batteries.
  3. Easy removal of waste batteries (Article 11)
    Manufacturers shall design products in such a way that waste batteries can be readily removed. This requirement is deemed to comply with in such cases where batteries can be removed by end-users or independent qualified professionals.

Response to RoHS 2 Directive

  1. Basic view
    The recital 14 of RoHS 2 Directive explicitly states the following:
    " This Directive should apply without prejudice to Union legislation on safety and health requirements and specific Union waste management legislation, in particular Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators and waste batteries and accumulators and Regulation (EC) No 850/2004."
    This means the Battery Directive has precedence over the RoHS 2 Directive for batteries and accumulators. Therefore, we are not in a position to submit a certificate or an agreement for batteries and accumulators regarding conformity with the RoHS 2 Directive. We appreciate your understanding.
  2. Restricted substances
    RoHS 2 Directive regulates the restriction of maximum concentration value by weight in homogeneous materials※ of electrical and electronic equipment (EEE) in Annex II as shown below. ※homogeneous materials means uniform composition that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes.
    1. Mercury 0.1%
    2. Lead 0.1%
    3. Cadmium 0.01%
    4. Cr+6 0.1%
    5. PBBs 0.1%
    6. PBDEs 0.1%
    7. DEHP 0.1%
    8. BBP 0.1%
    9. DBP 0.1%
    10. DIBP 0.1%
    Since RoHS 2 Directive does not apply to batteries and accumulators as aforementioned, the restriction of use of the above 10 materials is not applicable to our batteries. However, our alkaline batteries do not contain any of these 10 materials, so we can deliver an analysis report for our batteries simply as a certificate of non-use. The rule about homogenous materials described in article 3 (20) of RoHS 2 Directive is not applicable to batteries and accumulators, so we provide data analysis reporting based on battery weight.
  3. CE marking (not applicable to batteries)
    Article 7 of RoHS 2 Directive sets down the manufacturer's obligations when they place their products on EU market. Products bearing the CE marking is one part of these obligations. However, as aforementioned, RoHS 2 Directive does not apply to batteries and accumulators, hence our batteries and accumulators do not bear CE marking.

Correlation between Battery Directive and WEEE/RoHS Directive

If you are concerned about the correlation between the Battery Directive (applied to batteries and accumulators) and the WEEE/RoHS Directives (also known as EU environmental regulations), we would like to introduce the website of the battery Association of Japan (BAJ), where can find BAJ's official view on this matter.
http://www.baj.or.jp/e/recycle/recycle09.html

Response to REACH Regulation

  1. Is it necessary to register a battery in accordance with the REACH Regulation?
    Batteries are categorized as "articles" by REACH. Articles 7 (1) and 7 (5) of the REACH Regulation state that a producer or an importer of articles should register to the agency any substance contained in those articles, if both the following conditions are met:
    1. a) The substance is intended to be released under normal or reasonably foreseeable conditions of use, and
    2. b) The total weight of the substance contained in the article(s) exceeds one ton per producer or importer per year.
    Batteries are not such articles that contain substances that are intended to be released, but rather batteries are intended to supply electricity generated by an internal chemical reaction of the positive and negative electrodes.
    Therefore condition a) is not applicable and there is no obligation to register to the agency. For this reason, we cannot submit a certificate or an agreement for batteries in regards to compliance with the REACH Regulation. We appreciate your understanding.
  2. Our obligation to the REACH Regulation
      1. (1) Duty to communicate information on substances in articless
      1. Article 33 states "Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0.1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance."
      2. (2) Duty of compliance with restricted substances
      1. Article 67 states "A substance on its own, in a preparation or in an article, for which Annex XⅦ contains a restriction shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction." We comply with these requirements.

Response to SVHC Candidates

SVHC candidates can become subject to authorization and as a result, it is important to be aware of the most recent situation. We always monitor relevant information such as news releases from ECHA and carefully check whether newly announced SVHC candidate substances are contained in our components or not. Confirmation from our suppliers can take multiple days, so we would appreciate your understanding in case our response to any queries is delayed. Please feel free to contact our sales representatives for requests about SVHC candidate list.