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Battery companies how to deal with the eu REACH regulation

2016/6/16      view:

China's exports to the eu battery products generally include zinc-manganese batteries, alkaline manganese battery, a new type batteries, lead-acid batteries, nickel cadmium batteries, nickel-metal hydride batteries, lithium ion batteries and other batteries, battery materials, etc. In the REACH regulation, the battery products in general can be divided into two types: (1) excluding intended to release material "items", such as zinc manganese battery, alkaline manganese batteries, button batteries, etc. (2) "material/products, such as the electrolyte in the battery raw materials etc. Different types of battery products in the REACH of the responsibility is not the same, so the battery companies REACH to cope with the first step is to control the REACH of law and related guidelines, analysis their products in the REACH of the type and the need to perform the duty (for one product is difficult to identify, can enlist the help of a professional agency).


The following, this paper will be "dry cell" as the case for analysis. The analysis based on inspection and quarantine of China REACH resolution center in collaboration with companies such battery case analysis.


Now the battery industry to REACH a wrong understanding, think all matter in the battery, especially to participate in the electrochemical reactions in the battery material must be REACH (pre) registered. Dry cell in the definitions of the REACH regulation belongs to the category of "material", and the inside of the chemical composition is part of the battery.


Decision process is as follows:


Main function is to provide current and voltage is produced by electrochemical reaction between two different materials, at the same time in the two different electrode produce (e.g., the positive and negative), electrode was immersed in electrolyte (liquid or solid), no chemical reaction, the voltage will not produce. So the chemical composition is very important for function.


Battery of external and internal shape and design to ensure when needed reaction occurs in a controlled way, and continue to provide energy, and provided in the form of a kind of can use. Therefore, the shape of the battery and design for this feature is also important.


1. The electrolyte and electrode active material such as outside the battery can't provide any current. No battery specific design to fill into other containers, they cannot provide energy. Electrolyte battery container parts left, also is unable to perform its role. There are, however, may be of different types of electrolytes used in the same kind of batteries.


2. The electrolyte and electrode active material not released from the battery, so no transfer function and the release of don't control it.


(3), electrode materials and electrolyte battery container usually discarded together.


Conclusion, we should think for items, battery electrolyte and other chemicals as an organic part of batteries, and is "not intentionally release material".


Dry cell in the REACH of the responsibility for:


1. The responsibility of the registered: dry cells don't contain "intentionally release material", no need to fulfill the responsibility of the registered, except the European chemicals agency has asked;


2. The responsibility of reporting: scope for dry cell content more than 0.1% (w/w), and quantity more than 1 ton/year high attention of substance;


3. Responsibility: communication range of dry cell content more than 0.1% (w/w) of the high attention of substance;


4. The limit of liability: for dry cell contains the scope of REACH 17 all the material in the attachment.


Dry cell companies cope with the steps of the eu REACH regulation are as follows:


1. The listed companies to the European Union's trade types and quantity of the product has the dry cell.


2. Material composition analysis of dry cell; This step needs to communicate with raw material suppliers, such as zinc and zinc supplier for the material composition information, and the suppliers of electrolyte for electrolyte composition information, etc.


3. The material composition and dry cell in the REACH regulation in the "high attention matter" and "restricted substances" compare, look to whether meet the requirements of the REACH regulation.


Need to pay special attention to in the battery is about restrictions apply. In the REACH regulation, restrictions on June 1, 2009 formally implemented. But now the eu directive 76/769 / EEC, RoHS directive and WEEE directive has the content of the dangerous chemicals in related products made clear limits, such as the mercury content in the battery or the battery is more than 0.0005%, shall not be sold, the rules including electrical appliances in the matching of batteries or battery pack. Battery companies in dealing with the REACH regulation at the same time, also need to conform to the requirements of other eu regulations instruction at the same time, in order to make their products completely accord with the requirement of eu laws and regulations.


Because of the complexity of the battery products, to avoid the influence of the eu REACH regulation, Chinese inspection and quarantine REACH resolution center experts strongly recommended battery companies to analyze its exports to the eu product as soon as possible, and entrust a specialized REACH services to analyze its involving the product, to conduct a comprehensive analysis of battery products, and the need to REACH deal with material (pre) registered. The eu REACH regulation have mandatory start formally on June 1, 2008 (pre) registration procedure. Battery companies in China must firmly grasp the pre-registration before December 1, to do a good job of dealing with the REACH regulation.


A link to the


China's battery industry has developed rapidly, has now become the world's battery producer and exporter. In January 2008 to march, China's battery industry enterprises above designated size battery output value 4.7832 trillion yuan, up 48.2% from a year earlier. Sales value of 46.49 billion yuan, up 55.4% from a year earlier. Battery export volume accounts for battery production by about 80% in our country, the eu REACH regulation for battery had a greater influence on the export trade in our country. In previous, the European Union WEEE directive was implemented on August 13, 2005, the directive rules, the European Union to circulate on the market of electronic electrical equipment manufacturers must legally take responsibility to pay the cost of scrap recycling products, at the same time, the eu member state obligation to set their own electronic products recycling program, establish relevant recycling facilities, electronic electrical products to the end user can easily and tackling the equipment free of charge. Then on July 1, 2006, began the eu RoHS directive, the directive rules, electronic electrical equipment of the new eu market restrict the use of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PCBS) and polybrominated diphenyl ether 6 kinds of harmful substances.