Question: Because of the substances they contain, batteries are outside the scope of the Restriction of Hazardous Substances (RoHS) Directive. However, are batteries and battery packs impacted by the REACH Regulation?
Answer: Batteries are indeed outside the scope of the RoHS Directive due to Battery Directive 2006/66/EC, which regulates the manufacture and disposal of batteries.
However, batteries are still within the scope of the REACH Regulation, as an individual battery (or battery cell) is classified as an article.
Battery packs, meanwhile, are defined as “any set of batteries or accumulators that are connected together and/or encapsulated within an outer casing so as to form a complete unit that the end user is not intended to split up or open.” Assuming the pack is sealed, it would fall under Battery Directive 2006/66/EC, but the pack itself would be in scope of the REACH Regulation.
In short, Battery Directive 2006/66/EC labeling is applicable to batteries and potentially for sealed battery packs, while the REACH Regulation applies to all in-scope items, including a case and its components.
Article current as of 2019-08-02.