EU Battery Declaration Criteria

These guidelines are for informational purposes only and do not constitute legal advice. 

This guide provides Assent’s standard checklist for reviewing inbound supplier declarations regarding compliance with the substance restriction requirements of Directive 2006/66/EC (often called EU Battery). An acceptable declaration must:

  1. Be on company letterhead.
    This indicates that the declaration is an official company communication of the employee making the declaration.
  2. Include the proper legislative reference.
    Include the actual title of the legislation the declaration is being produced to comply with, in this case EU Directive 2006/66. Acceptable alternative names for the directive:
    1. Directive 2006/66/EC.
    2. Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC.
  3. Reference the product(s), part(s), or material(s) covered by the declaration.
  4. Declare compliance status. Either:
    1. State that the declaration does not include any of the substances defined by the directive at concentrations greater than the established limits, or
    2. State that the declaration does include substances defined by the directive at concentrations greater than the established limits, and identify the substance(s) creating non-compliance and the associated product(s).
      For any products that contain substances at over-threshold concentrations but are compliant due to specific use exclusions, the declaration must also identify the product(s) and cite the relevant exclusion(s).
  5. Be signed by an authorized individual.
    Name, contact details, and position must be included.
  6. Be dated, and current.
    Declarations are likely to be rejected if they are more than one year old.

Article is current as of 2020-05-06.


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