Are batteries within the scope of RoHS Directive?

No. Recital 14 of RoHS 2 specifically states that RoHS should apply without prejudice to the Batteries Directive. Recital 29 of the batteries and accumulators directive (2006/66/EC) states RoHS does not apply to batteries and accumulators used in electrical and electronic equipment.

RoHS Directive (2002/29/EC) restricts the use of certain hazardous substances and bans the use of lead, mercury, cadmium, hexavalent chromium, poly brominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) after July 1, 2006.

While the RoHS directive applies to electrical and electronic equipment, it does not currently apply to batteries. All batteries which comply with European Battery Directives are exempt from RoHS Directives.

The RoHS directive specifically excludes cells & batteries due to the precedence of the EU Battery Directive 91/157/EEC.This Battery Directive mandates specific recovery programs for batteries and battery assemblies to prevent any potentially harmful waste streams (WEEE). All batteries and battery packs by all battery manufacturers fall under the scope of Battery Directive 91/157/EEC and are exempt from the RoHS Directive.

How about Battery related Components?

Components used externally to the battery, such as components, connector covers, hardware, racks, solder, plastics, and other non-battery accessories, however, may fall within the scope of RoHS depending on the product application and other factors. OEMs have to gather information from the suppliers of such components concerning RoHS restricted substances and has used appropriate methods to ensure the accuracy of such information.

What is the relationship between the Batteries Directive and RoHS Directive?

Recital 29 of the Batteries Directive states that the RoHS Directive does not apply to batteries and accumulators used in electrical and electronic equipment. The Batteries Directive and the RoHS Directive have similar but different substance restrictions. The RoHS Directive restricts the use of heavy metals, such as mercury and cadmium, in electrical and electronic equipment but it does not apply to batteries. The Batteries Directive restricts the use of mercury and cadmium in batteries.