(EU) 2023/1542 · Annex XIII(1)(a) -> Annex VI, Part A(8)
Hazardous substances in a battery: the field asks about everything but three
The wording of this field is often misread. The regulation is not asking about mercury, cadmium and lead — because Annex I already restricts them with limit values. The field asks about everything else hazardous in the battery. That is a considerably broader question than it looks.
Why those three are carved out
Annex I restricts them directly: mercury at no more than 0.0005% by weight in any battery, cadmium at no more than 0.002% in portable batteries, and lead from 18 August 2024 at no more than 0.01% in portable batteries — with portable zinc-air button cells exempt until 18 August 2028. Since they are prohibited above those limits, listing them as “hazardous substances present” would serve no purpose.
So what belongs in the field
Every other hazardous substance actually present in the battery. In lithium-ion systems that is most often electrolyte components, solvents, conducting salts and certain cathode compounds. The source is not a catalogue but the supplier's safety data sheet and composition declaration.
The overlap with SCIP
If an article contains a REACH candidate list substance above 0.1% by weight, there is a duty to notify the SCIP database, in force since 5 January 2021. The data you need for this passport field overlaps heavily with that notification — anyone who has already handled SCIP has much of the work done.
What is still coming
Article 6(5) requires the Commission to prepare a report by 31 December 2027 on substances of concern present in batteries or used in their manufacture, and to consider follow-up measures including delegated acts. The list of restricted substances may therefore grow.
Where it goes wrong
- Listing mercury, cadmium and lead in this field — the regulation explicitly excludes them because it restricts them elsewhere.
- Leaving the field empty because “the battery contains no hazardous substances” — for lithium-ion systems this is almost never true.
- Using a generic chemistry safety data sheet instead of one for the specific battery.
- Maintaining SCIP data and passport data separately, although they largely concern the same substances.
Frequently asked
Why does the field exclude mercury, cadmium and lead?
Because Annex I already restricts them with limit values. The field in Annex VI, Part A, point 8 explicitly reads “other than mercury, cadmium or lead”.
What limits apply to those three?
Mercury 0.0005% by weight, cadmium 0.002% in portable batteries, lead 0.01% in portable batteries from 18 August 2024, with a transitional exemption for zinc-air button cells until 18 August 2028.
Can we reuse our SCIP data?
Largely yes. SCIP covers candidate list substances above 0.1% by weight and overlaps heavily with this field, though the two are not identical.
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