Classification of Batteries

Eucobat Positions
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PP Classification of Batteries - Sum.pdf 849.48 KB

Actual Situation

The battery directive[1]distinguishes following types of batteries:

  • Portable battery or accumulator’ means any battery, button cell, battery pack or accumulator that:
    • is sealed; and
    • can be hand-carried; and
    • is neither an industrial battery or accumulator nor an automotive battery or accumulator.
  • Industrial battery or accumulator’ means any battery or accumulator designed for exclusively industrial or professional uses or used in any type of electric vehicle.
  • Automotive battery or accumulator’ means any battery or accumulator used for automotive starter, lighting or ignition power.

This distinction is important, as it is decisive to determine the liabilities and responsibilities, as well operational as financial, of all concerned actors. 

In particular, the significance of the classification of the batteries is undisputable for the calculation of the collection target, as this only applies to portable batteries.

After several years of experience in the Member States, it seems that there is particularly a problem to distinguish industrial from portable batteries. 


The producers can relatively easily apply the actual definitions of the battery directive, as they know in most cases the intended use of the batteries they put on the market.

It is however much more difficult for the operational actors to apply these definitions, as they only receive the waste batteries and battery packs, without knowing the applications they were used in. They are obliged to use a set of criteria (see above) that differs from country to country.

The different interpretations in the Members States for the classification of the waste batteries into industrial and portable waste batteries have a serious impact on the reported collection rates. As a consequence, these differences make it very difficult to compare the figures of the Member States.

Furthermore, experience shows that the application of inappropriate criteria to distinguish the collected batteries leads to unrealistic collection rates in some Member States.

Besides the collection rates, the interpretation also influences the financing of the collection schemes. The distinction criteria should ensure that the producers of the batteries collected through the household collection take the financial responsibility for the operational costs related to the batteries they’ve put on the market.

Eucobat Proposal

The actual definitions correspond to an economical reality.

As indicated, the producers can relatively easily apply the current definitions for the batteries they put on the market, using the existing decision trees.

On the other hand, clear interpretation guidance is required for the operational actors for the collected batteries, in order to ensure that these operational actors classify the batteries in the same way.

In order to distinguish portable batteries from industrial waste batteries, the experience of the compliance schemes indicates that a weight limit of 5 kg corresponds to a certain reality and could be used as a criterion for the batteries that cannot be clearly identified as industrial batteries by visual inspection.

[1]The weight limit is not supported by Stiftung Gemeinsames Rücknahmesystem Batterien.

Market evolution

The market for new high performance lithium batteries is growing quickly and the batteries are used in new fields and new types of appliances. Some of these lithium battery systems require advanced and expensive recycling processes. 

Battery collection organisations are very concerned about fair competition and fair financing and they see the need for additional legislation. 

Such regulation should guarantee a level playing field for the collection, recycling and treatment of portable, industrial and automotive lithium batteries and should:

  • describe the requirement to create and maintain appropriate take-back structures for industrial and automotive batteries, and
  • Strictly avoid improper disposal of waste industrial or automotive batteries, and the cells they’re composed of, through collection schemes for portable batteries.