2011/65/EU - Battery Design

Directive 2011/65/EU (RoHS 2) is the European Union’s Restriction of Hazardous Substances Directive, restricting the use of specific hazardous substances in electrical and electronic equipment (EEE). It applies to a broad range of battery-related products including battery chargers, BMS electronics, inverters, and battery-powered consumer and industrial devices. While the directive does not apply directly to batteries themselves (which are regulated under the EU Battery Directive and Battery Regulation), it applies to the electronic equipment and systems that incorporate or charge batteries.

Legislation type: EU Directive
Reference: Directive 2011/65/EU (RoHS 2), amended by Directive 2015/863/EU (RoHS 3 — adding four phthalates)
In force: January 2013 (phased by product category)
UK equivalent: The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (UK RoHS)

Restricted Substances

RoHS restricts ten substances in EEE: lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr⁶⁺), polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), and four phthalates added by the 2015 amendment (DEHP, BBP, DBP, DIBP). Maximum concentration limits apply: 0.1% by weight in homogeneous materials for all restricted substances except cadmium (0.01%). Specific exemptions exist for applications where technically feasible alternatives are not yet available.

Relevance to Battery Engineering

RoHS compliance is relevant to battery engineers in several respects. Battery management system PCBs and their components must be RoHS compliant — in practice this means using lead-free solder and avoiding restricted substances in electronic components. Battery charger and power electronics hardware must similarly comply. While battery cells themselves are outside the direct scope of RoHS (they are regulated by the Battery Regulation), the complete battery system — including housing, connectors, wiring harnesses, PCBs, and displays — must comply if it constitutes EEE placed on the EU market.

The interaction between RoHS and the EU Battery Regulation is important: the Battery Regulation has its own restricted substance provisions (including limits on mercury, cadmium, and lead in specific battery types), and engineers must ensure that battery products satisfy both regulatory frameworks simultaneously. RoHS exemptions relevant to battery systems should be verified against the current exemption list, as exemptions have fixed expiry dates and require renewal.

Disclaimer: This is not a definitive guide, just an indication and it is important that you always go back to the source for legislation.