Question: Are batteries or battery manufacturers in scope of the EU Restriction of Hazardous Substances (RoHS) Directive?
Answer: No. Batteries are not in the scope of the RoHS Directive because they are regulated through the Batteries and Accumulators Directive 2006/66/EC, which restricts some (but not all) RoHS Directive substances, specifically mercury and cadmium. Recital 14 of EU RoHS 2 (Directive 2011/65/EU) specifically states that EU RoHS should apply without prejudice to the Batteries Directive. Recital 29 of the Batteries and Accumulators directive (2006/66/EC) states that EU RoHS does not apply to batteries and accumulators used in electrical and electronic equipment (EEE).
Some companies may not understand the distinction of scope between the two Directives and therefore request RoHS substance information for all components in their electronic products, including any embedded or removable batteries.
Content valid as of Sept. 20, 2019.