Compliance with Environmental Regulations

With growing global awareness of environmental protection and human health, various regulations have been established to control chemical substances, product design, marking, and end‑of‑life management of batteries.

In the European Union, comprehensive environmental legislation such as the REACH Regulation, the RoHS Directive, the EU Battery Regulation, and the EU POPs Regulation has been implemented, covering the entire battery life cycle.

In the United States, batteries are also subject to regional regulations, including the California Proposition 65.  Regulatory requirements applicable to batteries differ in some respects from those for electrical and electronic equipment (EEE), making it important to properly understand the scope and obligations of each regulation. Based on these regulatory frameworks, we manage chemical substances appropriately from the design and manufacturing stages and provide batteries that comply with applicable environmental regulations in each market. This page provides an overview of the principal environmental regulations relevant to our batteries.

The EU REACH Regulation (EC No. 1907/2006) is a comprehensive chemical regulatory framework aimed at reducing risks to human health and the environment through the registration, evaluation, authorization, and restriction of chemical substances.

Batteries are subject to the following compliance obligations as articles.

■Article 33 (Obligation to Communicate Information on SVHCs)

If a substance of very high concern (SVHC) is present in a component of a battery at a concentration exceeding 0.1%, we provide the name of the relevant substance free of charge to our customers at the time of the first delivery, and to consumers within 45 days upon request.

■Article 67 and Annex XVII (Restrictions on use)

If substances listed in the Annex XVII are present in a battery, we comply with the applicable conditions and restrictions regarding the manufacture, placing on the market, and use of such substances.

The RoHS Directive (Directive 2011/65/EU, as amended by Commission Delegated Directive (EU) 2015/863) is the EU regulation that aims to protect the environment and human health by restricting the use of certain hazardous substances in electrical and electronic equipment (EEE). Batteries are excluded from the scope of the RoHS Directive and are subject to the EU Battery Regulation.

However, our batteries do not intentionally use any of the 10 substances restricted by the RoHS Directive (lead, cadmium, mercury, hexavalent chromium, PBB, PBDE, DEHP, DBP, BBP, and DIBP), and we have confirmed that their content (100 ppm for cadmium and 1000 ppm for others per homogeneous material) is below the specified value.

For this reason, we are able to issue a "Non-Use Declaration" instead of a "Certificate of RoHS Compliance."

The EU Battery Regulation (Regulation (EU) 2023/1542) is a new comprehensive rule that replaces the former EU Battery Directive (2006/66/EC) and entered into force in August 2023. While the former directive mainly focused on collection and recycling, the new regulation takes a broader approach and covers the entire life cycle of batteries, from due diligence in raw material sourcing to design, manufacturing, use, collection and recycling.

The regulation applies to all batteries, and when batteries are sold in the EU or member states of the European Economic Area, economic operators in EU (importers, distributors, etc.) are required under the extended producer responsibility to register as producers in each country where batteries are sold and to report the amount of batteries collected, etc., in order to ensure the separate collection of waste batteries. Please note that the collection and recycling of batteries is a continuation of the Battery Directive and is not a new regulation under this regulation.

The Battery Regulation also applies to products that use batteries. Products incorporating portable batteries^*1 and LMT batteries^*2 must be designed so that the batteries can be easily removed and replaced by the end user (Article 11).

The Battery Regulation requires that compliant products bear CE marking and the separate collection symbol (crossed-out wheeled bin symbol). If the battery is too small to be labeled, it must be labeled on the packaging or accompanying documentation (Article 13). The small batteries listed on our product website comply with the substance restriction (Article 6) and are eligible for sale in Europe. Please note that, depending on the sales region, such as Japan, some products may not meet the labeling requirements applicable to sales in Europe. For further details, please contact us.

Furthermore, the Battery Regulation has different requirements depending on the battery category. Portable batteries^*1 and industrial batteries^*3 with a capacity of 2 kWh or less are exempt from carbon footprint regulations (Article 7), recycled content (Article 8) and digital battery passport (Article 77). For batteries in the relevant categories, such as EV and LMT, we will proceed with compliance on a phased basis based on the status of secondary legislation for each requirement.

*1 Portable battery: A sealed battery weighing 5 kg or less that is not specifically designed for industrial use.
*2 Light Means of Transport battery: A sealed battery under 25 kg for powering light electric vehicles, excluding EV traction batteries.
*3 Industrial battery: A battery specifically designed for industrial use, or one prepared for reuse or repurposing, or a battery weighing more than 5 kg.

The EU POPs Regulation (Regulation (EU) 2019/1021) is the European Union regulation that restricts the manufacture, use, and placing on the market of persistent organic pollutants　(POPs).

It is a powerful regulatory framework that applies immediately and directly to all member states, and does not require additional domestic legislation, enabling uniform management within the EU.

Our batteries do not contain any substances subject to the EU POPs Regulation.

The California Proposition 65 (the Safe Drinking Water and Toxic Enforcement Act of 1986) is a state law that requires clear and reasonable warnings to be provided when products sold in the State of California contain certain chemicals that may cause cancer or reproductive toxicity above specified exposure levels. The chemical substances on the state's list are updated regularly.

Batteries are sealed in metal cases, and under normal conditions of use, chemical substances contained in the batteries are not exposed to the human body. Accordingly, such products do not meet the definition of “exposure” under California Proposition 65, then, we have recognized that a warning label is unnecessary.