|Certificate of conforming to EU Battery Directive|
|We hereby certify that our all batteries delivered to you are conforming to Directive 2006/66/EC of the European Parliament and the Council of 6 September 2006 on batteries and accumulators so called “EU battery Directive”. According to this directive, restricted substances are cut down from 3 kinds of previous directive (91/157/EEC) to 2 kinds, however, additional requirements of “Labeling” and “Removal of waste batteries and accumulators” were newly laid down.
The restricted substances shown below are not involved in our batteries more than concentration by weight shown below;
Symbol which means separate collection shall be marked on all batteries in EU market. We marks symbol on the body of battery in case of cylindrical and prismatic batteries, or marks it on packaging in case of small batteries like coin batteries.
|How to deal with RoHS recast directive in case of batteries?|
|1.||Our basic position
In EU market, the Battery directive (2006/66/EC) applies to all batteries and accumulators, so RoHS recast directive (2011/65/EC) does not apply to any batteries and accumulators.
This, above mentioned, is stated in recital 14 of RoHS recast directive as follows.
|Hence we cannot respond to your request for submitting document like certificate
or agreement of batteries and accumulators which shall comply with RoHS
recast directive. We appreciate your understanding.
RoHS recast directive regulates the restriction of maximum concentration value by weight in homogeneous materials of electrical and electronic equipment (EEE) in Annex II as shown below.
|Because RoHS recast directive does not apply to batteries and accumulators as aforementioned, the restriction of use of above 6 materials is not applicable too. Our Lithium batteries, however, do not involve any 6 materials, so we can guarantee no use of above 6 materials regardless of no-applicability to RoHS.
Nevertheless, such rule that homogenous materials (uniform composition that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes) described in article 3 (20) is not applicable, so we will deliver the analysis report of whole battery as a certificate of no use of 6 materials.
Article 7 of RoHS recast directive stated about manufacturer’s obligations in case of placing their product which complies with RoHS directive on EU market. The obligation of bearing CE mark is the most important part in those obligations, however, as aforementioned; RoHS recast directive does not apply to batteries and accumulators, so we will not mark “CE” on our batteries and accumulators.
|Relationship between Battery directive and WEEE/RoHS directive|
|If you would concern about relationship between Battery directive which exclusively applies to batteries and accumulators and WEEE/RoHS directive as well-known EU environmental regulations, we would like to introduce home page of Battery association of Japan, it may be of your assistance knowing official view of battery association to this issue.
|What is necessary to deal with batteries regarding REACH regulation?|
|1)||Is battery necessary to register on the basis of REACH regulation?
Battery is categorized by “article”.
Though “substances” are used in battery as internal components, we have no obligation to resister them because our batteries are not manufactured in EU territory.
Article 7(1) and 7(5) of REACH regulation states that any producer or importer of articles shall submit a registration to the agency for any substance contained in those article, if both the following conditions are met;
a) The substance is intended to be released under normal or reasonably foreseeable conditions of use, and
b) The substance is present in those articles in quantities totaling over one tone per producer or importer per year.
Battery is not such article that intends to release any substance outside but intend to supply electricity generated by internal chemical reaction of negative and positive electrode. The condition a) is not met, so we have no obligation to submit registration to agency. Hence we cannot respond to your request for submitting document like certificate or agreement of batteries to be compliance with REACH regulation. We appreciate your understanding.
|2)||Our obligation to REACH regulation
Article 33 of REACH regulation requires that any supplier of an article containing a substance listed in authorization list in a concentration above 0.1% weight by weight (w/w) shall provide the recipient of the article information on, available to the supplier, so allow safe use of article including, as a minimum, the name of that substance, and the relevant information shall be provided, free of charge, within 45 days of receipt of the request, so Article 33 is only our obligation.
|Our action to SVHC candidate substances|
|Substances on the SVHC candidate list under REACH are simply chemicals “running for election” to be on the Authorization list, so they are just candidates but can be nominated to add Authorization list. Having regard to importance of this, we are always monitoring relevant information like News release from ECHA and taking action of confirmation whether or not new announced SVHC candidate substances are involved in our components. Our action; for example, delivering query to and collection from suppliers may take a long time, so we appreciate your understanding if we delay to answer.
Please contact our sales representatives for request about SVHC candidate list.