Guidance

Classifying portable and industrial batteries

Updated 25 August 2022

This guidance explains the definitions of, and how to classify, the battery types under the:

• Batteries and Accumulators (Placing on the Market) Regulations 2008 (the 2008 regulations)
• Waste Batteries and Accumulators Regulations 2009 – England only (the 2009 regulations)

The guidance describes how the Department for Environment, Food and Rural Affairs (Defra) and the regulators consider:

• when a battery is a portable battery or an industrial battery
• if a battery is designed exclusively for industrial or professional use

The guidance is for:

• industry
• Environment Agency staff
• Office for Product Safety and Standards staff

Automotive battery

An automotive battery is a battery of any size or weight used for one or more of the following purposes:

• starter or ignition power in a road vehicle engine
• lighting power in a road vehicle

Industrial battery

An industrial battery or battery pack is of any size or weight, with one or more of the following characteristics:

• designed exclusively for industrial or professional uses
• used as a source of power for propulsion in an electric vehicle
• used as a source of power for electrical propulsion in a hybrid motor vehicle
• unsealed but not an automotive battery
• sealed but not a portable battery

Portable battery

A portable battery or battery pack is a battery which meets all the following criteria:

• sealed
• weighs 4kg or below
• not an automotive or industrial battery
• not designed exclusively for industrial or professional use

Battery pack

A battery pack is a set of batteries connected or encapsulated within an outer casing which is:

• formed and intended for use as a single, complete unit
• not intended to be split up or opened

Sealed battery

The 2008 and the 2009 regulations do not define a sealed battery. Defra and the regulators have adopted the International Electrotechnical Commission’s (IEC) definition of a ‘sealed cell’. The IEC reference 482-05-17 defines a sealed cell as:

A cell which remains closed and does not release either gas or liquid when operated within the limits specified by the manufacturer.

Note – A sealed cell may be equipped with a safety device to prevent a dangerously high internal pressure and is designed to operate during its life in its original sealed state.

Defra and the regulators consider a battery which has a valve to allow the release of gas for safety purposes to be sealed. This includes valve regulated lead acid (VRLA) batteries.

A VRLA battery with a valve as a safety mechanism is sealed. A sealed battery weighing 4kg or below, which is not an automotive or industrial battery, is a portable battery.

A VRLA battery is designed to:

• keep the elements of the battery within the case – including gases normally produced during operation that are re-absorbed and kept inside the battery by chemical reactions which recombine the gases
• have a one-way valve to safely release any excess gas that cannot be reabsorbed
• prevent spillage or case rupture by build-up of gas pressure
• not need maintenance such as the need to refill with electrolyte during its lifetime

A VRLA is not a vented battery. Vented batteries are designed to:

• release gases or liquids through vents as they are produced during normal operation, so not reabsorb them
• allow additional electrolyte to be added during its lifetime

When a battery is not designed exclusively for industrial or professional use

Any battery weighing more than 4kg is classed as industrial or automotive.

Sealed batteries weighing 4kg or below may still be classed as industrial if they are designed exclusively for professional or industrial use.

If a battery producer wants to classify a battery as designed exclusively for professional or industrial use, weighing 4kg or below, they must provide evidence for that classification.

Defra and the regulators take the following into account when assessing if a battery is designed exclusively for industrial or professional use.

If the battery is available for the general public to buy

If the specific model of battery is widely available for the general public to buy, then it’s highly unlikely that its designed exclusively for industrial or professional use.

If the battery is sold with suggested uses which are not exclusively industrial or professional

It is highly unlikely that the model of battery is designed exclusively for industrial or professional use if:

• it is described as suitable for use within many different items or sectors
• any of these suggested uses are not exclusively industrial or professional

Some examples of uses that would not be considered exclusively industrial or professional include:

• an ‘off the shelf’ security or alarm system
• an ‘off the shelf’ fire system
• children’s electronic toys
• solar power storage
• uninterruptable power supply (UPS)

Any models of batteries which are described as suitable for ‘general’ or ‘generic’ use are highly unlikely to have been designed exclusively for industrial or professional use.

Suggested evidence

A battery producer could source a manufacturer data sheet for their specific model of battery as evidence in support of the battery having been designed exclusively for professional or industrial use.

Where the regulator disagrees with the classification of a battery, they will ask the battery producer to provide written confirmation from the battery manufacturer that its specific model number is designed exclusively for industrial or professional use.

Such written confirmation alone does not prove that the battery is exclusively designed for industrial or professional use. Other supporting evidence must also be provided. For example, simply using the term ‘industrial battery’ describing the battery in a manufacturer’s literature or on their webpage is not enough evidence.