Business and enterprise – guidance

Placing batteries on the market: producer responsibility

Find out what you need to do to legally place batteries or accumulators on the UK market.

If you design or manufacture any type of battery or accumulator for the UK market, including batteries that are incorporated in appliances, they must conform to legislation.

Find out the definitions of the types of batteries that are regulated.

Prohibited materials

You must not place batteries on the market if they contain more than:

  • 0.0005% of mercury by weight
  • 0.002% of cadmium by weight
  • 0.004% of lead by weight

There are exceptions to these limits, which are explained below.


Button cells can contain up to 2% mercury by weight if marked Hg if they are placed on the market before 1 October 2015.


The following types of battery may contain more than 0.002% of cadmium if they are labelled Cd:

  • portable batteries intended solely for alarm systems, emergency lighting and medical equipment
  • cordless power-tools placed on the market before 1 January 2017
  • industrial batteries
  • automotive batteries


Any battery may contain more than 0.004% of lead if it is marked Pb.

Labelling batteries correctly

All labelling on batteries must be visible, legible and indelible.

Crossed out wheeled bin

Batteries must be labelled with the symbol of a crossed out, wheeled bin, as shown below.

Crossed out wheeled bin

This symbol must cover:

  • at least 3% of the surface area of the largest side of a non-cylindrical battery or battery pack, or
  • at least 1.5% of the total surface area of a cylindrical battery, and, in either case, up to a maximum size of 5 x 5 centimetres (cm)

If a battery is so small that the size of the symbol would be less than 0.5 x 0.5 cm, then you must place the symbol on the packaging, but it must be at least 1cm x 1cm.

Where a battery is provided within another piece of equipment and it is impractical to mark the battery, the symbol must be marked on the packaging of the product.

Chemical symbols

Any chemical symbols required must:

  • be directly below the crossed out wheeled bin and
  • cover an area of at least 25% of the crossed out wheeled bin symbol

Capacity labelling

You must label:

  • portable rechargeable batteries with their capacity in milliampere-hours (mAh) with a whole number or ampere-hours (Ah) with only one digit after the decimal point
  • automotive batteries with their capacity both in ampere-hours (Ah) and in cold cranking amperes (A), written as whole numbers

Make sure the minimum size and location of capacity labels on batteries is as shown in the following table:

Type of battery Location of marking Minimum size of label on battery or battery pack (height x length) Minimum size of label on packaging (height x length)
portable rechargeable (except button cells and memory back up batteries) on the front of the packaging and on the individual batteries. If sold without packaging, on the battery or accumulator 1.0 x 5.0 mm 5.0 x 12.0 mm
rechargeable battery packs where the largest side is equal to or above 70 cm squared on the external housing of the cell’s assembly (individual cells inside the housing do not require marking) 2.0 x 5.0 mm not applicable
rechargeable battery packs where the largest side is below 70 cm squared on the external housing of the cell’s assembly, individual cells inside the housing do not require marking 1.0 x 5.0 mm not applicable
button cells and memory back-up batteries on the front of packaging not applicable 5.0 x 12.0 mm
automotive batteries and accumulators on the largest side of the battery but not on the bottom side covering at least 3% of the area up to a maximum of 20 × 150 mm not applicable

If the size of the battery, accumulator or battery pack is too small to be suitably marked, the capacity must be marked on the packaging with a minimum size of 5.0 × 12.0 mm (height x length). If it is not supplied with its own packaging, the capacity must be marked on the packaging of the appliance it is sold with.

Making batteries readily removable

You must design appliances that incorporate batteries so that the person using the appliance can readily remove the battery. This means that they should be able to remove it safely and without difficulty, using the instructions provided where necessary. Where it is not possible for the battery to be readily removed by the person using the appliance, an independent qualified professional must be able to readily remove it.

Appliances incorporating batteries must be accompanied by instructions which explain how the battery can be readily removed by either the person using the appliance or an independent qualified professional. The instructions must explain the type of battery incorporated, where appropriate.

This does not apply where a permanent connection between the appliance and the battery is needed for safety, performance, medical or data integrity.

Some products, such as toys, must comply with specific rules on how batteries can be removed. Manufacturers must make sure they meet these requirements.

Enforcement guidance

The legislation is enforced by the National Measurement and Regulation Office (NMRO).

Enforcement officers may visit premises at any reasonable time. They may inspect batteries, examine procedures and request records. They may also seize batteries or records.

If you have not complied with the regulations, you may be given an enforcement notice. This will tell you what the problem is and what you need to do about it within a specified time. Persistent and / or serious breaches can lead to prosecution.


Download guidance on the appeals process associated with the enforcement of this legislation by the NMRO.

NMRO appeals guidance


Legal responsibilities when placing batteries on the market:




You can make any enquiries using the NMRO online enquiries system.

Alternatively, you can phone 020 8943 7227 and leave a message and an enforcement officer will return your call as soon as possible. This is an automated system and you will not be able to speak with anybody on this number.

You can also send enquiries in writing to:

NMRO Enforcement Services
Stanton Avenue
TW11 0JZ

The advice provided by the NMRO enquiry service is based on the best and most up to date information available at the time. The NMRO aims to respond to all enquiries within one month.