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Relationship between the Batteries Directive and the WEEE & RoHS Recast Directives

This document intends to clarify the relationship between the Batteries Directive (2006/66/EC) and the RoHS Recast Directive (2011/65/EU) and WEEE Recast Directive (2012/19/EU).

The WEEE Recast Directive (2012/19/EU) states in Article 8, Section 2 that the parts and materials, which may have harmful effects on the environment, shall be removed from the collected electrical and electronic equipment (hereinafter referred to as equipment) prior to processing. In its annex Ⅶ, those materials and parts which are required selective removal and treatment are listed and batteries are on the list. Therefore batteries shall be taken out prior to processing under WEEE Directive, and then the batteries separated from WEEE shall be treated according to Batteries Directive.

In addition, the following is mentioned in the RoHS Recast Directive (2011/65/EU), recital (14). It says that, for the batteries, the Batteries Directive shall be applied without prejudice to other Directives in EU.

(14) This Directive should apply without prejudice to Union legislation on safety and health requirements and specific Union waste management legislation, in particular 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 Regulation (EC) No 850/2004

Exclusion of the batteries from the scope of RoHS Directive is confirmed in recital (29) of the Batteries Directive, which was published in September 26, 2006, as follows.

(29) Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment does not apply to batteries and accumulators used in electrical and electronic equipment.

The selective removal of batteries from WEEE is also required by Article 12 Section 3 of the Batteries Directive 2006/66/EC.

3. Where batteries or accumulators are collected together with waste electrical and electronic equipment on the basis of Directive 2002/96/EC, batteries or accumulators shall be removed from the collected waste electrical and electronic equipment.

BAJ hereon interprets the relationship between the Batteries Directive and WEEE & RoHS Recast Directives as follows.

A similar interpretation has been mentioned in Section 4 of the "Question and Answers on the Batteries Directive (2006/66/EC)" issued by the European Commission.


The marketing restriction, as provided for the RoHS Recast Directive, on equipment  containing hazardous substances (6 substances such as mercury, cadmium and lead) does not apply to batteries used with or incorporated in equipment.


WEEE Directive applies to spent batteries collected together with WEEE (embedded, attached or included), and requires their removal from WEEE and separate collection before processing WEEE. After the separation from the equipment, the batteries shall be processed in accordance with the Batteries Directive.


The Batteries in line with Batteries Directive, Article 4, are possible to use in the equipment.

Definition of “Battery”:
Based on the above, BAJ interprets that "battery" is the battery unit which is properly marked, designed to be easily removable, and has to be collected according to the regulations.


* RoHS Recast Directive:
Directive on the restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (2011/65/EU), published in July 1, 2011.
* WEEE Recast Directive:
Waste Electrical and Electronic Equipment (2012/19/EU), published in July 24, 2012.