Chemistry labelling

Chemistry labelling identifies the chemistry of a battery and the hazardous substances it contains, on the label and in the underlying record. Article 13 and Annex VI require general information that includes chemistry and hazardous substances other than mercury, cadmium, and lead, plus the chemical symbols Cd and Pb where the battery contains more than 0.002 percent cadmium or more than 0.004 percent lead by weight. The chemistry statement must use a recognised name or code for the chemistry, and must match the composition record for the battery model. A chemistry name that describes a marketing family rather than the actual cell chemistry does not meet the test, because a recycler, a repairer, and a safety assessor each rely on the actual chemistry.

Chemistry labelling means the statement of battery chemistry and hazardous substances on the label, supported by the composition record. The scope covers all batteries for the general information label, and all batteries for the Cd and Pb symbols where thresholds are exceeded.

What is the legal frame for this marking?

Chemistry labelling is a physical marking duty and a record duty at the same time. A composition analyst confirming chemistry and substance data for a label should work from the current consolidated text and check whether an implementing act on harmonised label specifications has entered into force, since Article 13 sets some dates by reference to that act. A lithium iron phosphate battery should be labelled with that chemistry in a form that a recycler can recognise, with hazardous substance information that matches the safety data for the cells used.

How are content, placement, and legibility checked?

Content asks whether every required element for chemistry labelling is present and correct for the battery category. The composition record, substance data, and label artwork should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Critical raw materials present above 0.1 percent by weight, including cobalt, lithium, and natural graphite where relevant, are part of the general information label, and the threshold and the basis of calculation should be recorded.

How does category decide content?

Category decides content. For chemistry labelling, the record should state the category as defined in Article 3, list the label elements that apply to that category, and list the elements that do not apply, with the reason. A composition analyst confirming chemistry and substance data for a label should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A lithium iron phosphate battery should be labelled with that chemistry in a form that a recycler can recognise, with hazardous substance information that matches the safety data for the cells used.

How are measurement and wording recorded?

For chemistry labelling, a capacity value, a chemistry statement, or a duration value should name the test method, the conditions, and the unit, so the same battery tested again gives a comparable result. The composition record, substance data, and label artwork should include the test report or the calculation sheet, the date, and the person or function that approved the value. Critical raw materials present above 0.1 percent by weight, including cobalt, lithium, and natural graphite where relevant, are part of the general information label, and the threshold and the basis of calculation should be recorded.

What sits behind the marking in the documentation?

For chemistry labelling, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A composition analyst confirming chemistry and substance data for a label should check that the declaration date, the battery model, and the marking version are consistent, and that a change to the battery that affects conformity leads to a review of the documentation. A lithium iron phosphate battery should be labelled with that chemistry in a form that a recycler can recognise, with hazardous substance information that matches the safety data for the cells used.

How is a marking checked line by line?

For chemistry labelling, a checker should compare the physical marking, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the technical documentation, line by line, and record each comparison with a pass, a fail, or a query. The composition record, substance data, and label artwork for the check should include the date, the sample identifier, and the version of each document compared. A composition analyst confirming chemistry and substance data for a label should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Critical raw materials present above 0.1 percent by weight, including cobalt, lithium, and natural graphite where relevant, are part of the general information label, and the threshold and the basis of calculation should be recorded.

How is a chemistry label checked against composition?

Checking a chemistry label starts with the composition record for the model, which lists the cell chemistry, the active materials, and the hazardous substances with quantities. The label chemistry name is compared with the composition record, the Cd and Pb thresholds are checked against the substance quantities, and the critical raw material entries are checked against the 0.1 percent threshold. A worked check for one model shows the composition quantities, the threshold calculations, and the label entries, with the analyst and date. A chemistry name that describes a product family, where the composition record shows a different cell chemistry, is a failed check, and the label is corrected to the composition record, not the other way round.

Chemistry on a label is a safety and recycling fact, and a vague chemistry name leaves the next handler without the information the label was meant to give.