(EU) 2023/1542 · Annex XIII(1)(s) -> Article 74(1)(d)
Safety instructions for waste batteries: a document for a damaged one
Whoever reads this field is holding a battery in a condition your product documentation does not describe: spent, possibly deformed, wet, at an unknown state of charge, or already vented. Point (d) requires the necessary safety instructions to handle waste batteries, including in relation to the risks associated with, and the handling of, batteries containing lithium. Lithium is named expressly in the text of the Regulation, which means a general warning to take care does not satisfy the requirement.
A transport document is not the answer
A UN 38.3 test summary, dangerous-goods transport paperwork and the user manual all describe an intact battery in a known state. A waste battery is generally not in that state. Reusing transport documentation as the point (d) safety instruction leaves the actual hazard undescribed — thermal runaway in a damaged cell, what to do after water ingress, how to recognise a swollen housing.
Do not confuse it with paragraph 2 of the same article
Article 74(2) is a separate obligation: producers make available to distributors and the operators referred to in Articles 62, 65 and 66, and other waste management operators, information on safety and protective measures, including occupational safety, applicable to the storage and collection of waste batteries. That is a different audience, and Annex XIII does not pull that paragraph into the passport — point (s) of part 1 of Annex XIII covers only points (a) to (f) of Article 74(1). Companies routinely write one document and end up with occupational-safety text in a public field.
Why lithium is named separately
Because the risk of a waste lithium battery differs from the in-use risk, and the person at the collection point cannot assess it by looking. An instruction that is actually useful says concrete things: how to isolate the battery and protect the terminals, what to do after mechanical damage, what not to do when a thermal event is suspected, and at what point this stops being a job for a storeman and becomes one for the fire service.
Where it goes wrong
- UN 38.3 or dangerous-goods transport documentation used as the end-of-life safety instruction.
- Occupational-safety text from Article 74(2) placed in the public passport field.
- No lithium-specific handling at all, although point (d) names it expressly.
- Instructions that assume an intact battery at a known state of charge.
- A safety instruction that contradicts the use-phase extension advice under point (a).
Frequently asked
Is a safety data sheet enough?
No. Point (d) does not ask for substance properties but for instructions on handling the waste battery as an object, including lithium risks. These are different documents with a different reader.
Does the text under Article 74(2) also go into the passport?
No. Point (s) of part 1 of Annex XIII pulls only points (a) to (f) of Article 74(1) into the passport. The paragraph 2 obligation still exists, but it is addressed to distributors and waste management operators.
Who should write this text?
It is authored by the producer or the appointed producer responsibility organisation, but it will not be useful without two inputs: the cell manufacturer's knowledge of how the chemistry behaves when damaged, and the waste operator's experience of the condition batteries actually arrive in.
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