This guide explains what importers and exporters must know about regulations and standards applicable to lithium batteries in the European Union. Keep reading, and learn more about the EU Battery Directive, General Product Safety Directive (GPSD) and EN standards.
- Lithium Battery Powered Devices
- Lithium-ion battery
- Lithium-ion polymer battery
- Lithium metal battery
EU Battery Directive
The EU Battery Directive regulates all lithium batteries imported and sold in the EU market. Similar to the RoHS Directive, it also sets limits for the use of certain heavy metals in lithium batteries. That said, the Battery Directive covers additional heavy metals, and with stricter limits.
Here are some examples of restricted substances under the EU Battery Directive:
- Lead (less than 0.0004 % by weight)
- Mercury (less than 0.0005 % by weight)
- Cadmium (less than 0.002 % by weight)
Not all batteries are compliant
Far from all lithium batteries on the market are ‘designed for compliance’ with the EU battery directive. As such, we recommend that you procure lithium batteries (or other batteries for that matter) from well known and established brands – for example, Samsung or TDK.
Another option is to book third-party lab testing. That said, lab testing normally costs at least a few hundred dollars, which makes the total unit cost higher when buying OEM batteries without pre-existing test reports, compared to brand name batteries. Further, there’s no guarantee that an OEM lithium battery can even pass testing.
General Product Safety Directive (GPSD)
The GPSD covers lithium battery products, to protect consumers from potential hazards.
The GPSD provides relevant EN standards, often voluntary to ensure a high level of product safety. For instance, lithium batteries’ importers shall comply with EN 62133 and EN 60086-4 standards.
In addition, importers can often find specific requirements for their products in EN standards. For example, EN 60086 requires that imported products must bear a children’s warning label on the packaging of lithium batteries.
Importers shall self-issue a risk assessment to evaluate the potential hazards and risk levels. The risk assessment shall allow consumer access to product safety, and include other relevant information such as:
- Potential hazards identification
- Potential harm
- Severity of harm
- Probability of harm
- Risk level
- Action to the risk
While GPSD provides voluntary national standards (e.g EN standards) for product safety, the EN standards are also widely used to improve the product’s quality and performance. EN standards provide specific test methods and procedures to help importers and manufacturers to reach high quality.
For lithium battery products, EN standards provide typical specifications and technical solutions that can be served as a reference point at the product design stage. Following EN standards is generally not mandatory but highly recommended.
Relevant EN Standards for Lithium Batteries
- EN 60086-4 – Safety of lithium batteries
- EN 62133 – Safety requirements for portable sealed secondary cells
- EN 61960 – Specifies performance tests, designations, markings, dimensions and other requirements for lithium battery products
You can find more additional EN standards that apply to your product on shop.bsigroup.com.
Testing companies have the capability to conduct a wide range of test standards to verify whether your products are compliant, or need further improvement.
Far from all lithium batteries are designed for compliance with EN 60086-4, and other European Union standards. As mentioned, our recommendation is that you or your manufacturer procure brand name batteries from Samsung, TDK or other recognized brands. Such brands can provide pre-existing lab test reports, meaning that you don’t need to spend money on third-party safety testing. Buying OEM batteries can be cheaper on a unit cost basis, but when factoring in testing costs, that’s rarely the case.
The WEEE Directive applies to lithium batteries imported and sold in the EU. As such, importers need to bear a WEEE symbol on the lithium battery to reduce the environmental impact.
The WEEE symbol must be permanently and visibly printed on the battery and its packaging.
WEEE label file
Similar to the CE mark, importers shall provide the WEEE label file then submit to the supplier before the manufacturing process.
Directive on Waste Electrical and Electronic Equipment (Link)
Products that contain lithium batteries: CE Marking
Stand-alone lithium batteries or cells may not require CE marking. However, products that contain lithium batteries might be covered by one or more CE directives such as the EMC Directive, RoHS Directive, Radio Equipment Directive or others.
In such cases, importers must comply with the relevant CE directives and CE mark the products.
CE label file
Importers shouldn’t expect their suppliers to provide the CE label file. Instead, importers must provide CE label file in .ai or .eps file, then instruct suppliers with the following information:
- Print type
Note: CE mark shall be also printed on the product packaging and user manual if applicable.
Importers or manufacturers are also responsible to bear a permanent traceability code on the product and its packaging. The code shall at least include the following information:
- Manufacturing date
- Production facility
- Country code
Attaching a compliance mark on your product is not enough for CE compliance. Importers must also comply with another documentation requirement.
Here is an overview of the required documents:
Declaration of Conformity (DoC)
The Declaration of Conformity is a primary document that often requested by other authorities or organizations. Importer or manufacturer shall issue the DoC with the following information:
- Produce description
- Product features
- Name and address of the manufacturer/importer
- List of EN standards or directives
- Responsible individual contact
Importers or manufacturers shall provide a user manual for their lithium battery-powered product, with information such as:
1. Instructions on how to install the product
2. An overview of the relevant parts and part names of the product
3. Safety instructions
4. Instructions on how to use the product
5. Instructions on how to recharge and/or refill the product and
6. Instructions on how to dispose of the product in an environmentally friendly manner
Note: Compliance mark (e.g CE mark) shall be printed in the user manual as well.
The technical file is somehow similar to the product specification which includes product design, material, packaging, and labeling information. Importers shall at least include the following information:
- Bill of materials
- Design drawings
- Label files
- Packaging files
- List of applied standards and directives (e.g. EMC Directive)
- Test reports
- QC reports
- Risk assessment
All relevant test reports must be attached to the documents according to the applicable standards or regulations stated.
Amazon has a strict policy on lithium battery products. Before you list your products on Amazon, you must ensure the compliance and submit relevant test report and certification to get approval.
Safety Data Sheet (SDS)
Amazon generally requires importers to submit an SDS for their lithium battery products. The SDS shall include information such as:
- Product description
- Product usage
- Potential hazards and safety instruction
- Disposal instruction
- Storage instruction
Note: Failure to provide an SDS can result in delays in processing your shipments or even cancellation of deliveries.
Amazon FBA requirements
All product specifications, certification, and test reports shall be submitted to the fulfillment by Amazon (FBA), otherwise, your lithium product may be blocked for sale.
Lithium-ion batteries restrictions
High stored energy lithium-ion battery needs to comply with the restrictions set by each country, as it could cause harm during transportation. Here are some Amazon approval status examples:
- Canada – 0 Wh-100 Wh (Approved)
- Canada – 101 Wh-300 Wh (Rejected)
- China – 0 Wh-100 Wh (Approved)
- China – 101 Wh-300 Wh (Rejected)
- India – 0 Wh-100 Wh (Approved)
- India – 101 Wh-300 Wh (Approved)
- India – More than 301 Wh (Approved)
All lithium-ion batteries are required to be UN 38.3 compliant prior to shipping. UN 38.3 ensures that the packaging and shipment of lithium batteries meet the required standards including:
- UN 3090: Lithium metal batteries
- UN 3480: Lithium-ion batteries
- UN 3091: Lithium metal batteries contained, or packed with equipment
- UN 3481: Lithium-ion batteries contained, or packed with equipment
Compliance with UN 38.3 is a must for transporting lithium batteries. We suggest that you should obtain a UN 38.3 test reports from the supplier or third-party testing companies. Otherwise, most freight forwarders will not take the risk to ship your lithium batteries products.
ADR is the European Agreement concerning the international carriage of dangerous goods by road. Lithium batteries are classified as dangerous goods in class 9.
As such, you must attach a designated warning label 9A on the lithium-ion batteries, and comply with ADR packaging requirements before shipping the products to the EU.