Helping you choose the best solution for your battery power needs: consulting, design and supply

Regulations

Battery and Waste Battery Regulations

Material content, marking and waste regulations apply to batteries (EU Directive 2006/66/EC) and H-Squared can support you towards meeting any obligations you may have.~
  • All batteries supplied by H-Squared meet the contents and marking requirements of the regulations.
  • If you manufacture or import batteries into the UK then you may be a producer and be required to join one of the approved Battery Compliance Schemes.
  • If you sell batteries to end users then you should contact one of the approved Battery Compliance Schemes to set up collection arrangements.
  • If you have waste general purpose portable batteries then you can return them to any battery retailer or distributor that allows such access.
  • Alternative arrangements may also be available. H-Squared has teamed up with BatteryBack, one of the larger Compliance Schemes, for their support with battery disposal. Please contact them directly for further information.
  • If you have waste industrial batteries (batteries solely for use in professional devices), then the producer will provide further details about disposal.

Transportation of Lithium Batteries

Lithium batteries offer many advantages - higher energy density, wide operating temperature, long shelf life, and excellent high current performance.

However, their transportation is regulated (new and used, standalone or with equipment). In fact the regulations classify all lithium batteries as dangerous goods, but then list a series of exemptions subject to certain conditions (mainly the size and capacity of the battery).

The key requirements of the regulations for land and sea transport are:
  • It is the responsibility of the shipping organisation to ensure that the regulations are met. This applies to your supplier, and most probably, your organisation when they are transported further.
  • All lithium batteries must have passed international safety tests (UN Tests) - (although it is possible to ship small quantities of untested batteries in special containers).
  • Many tested lithium batteries are exempt from the main regulations and can be shipped unrestricted apart from some special labelling.
  • Those few that are sufficiently large (eg D and C size primary, rechargeable packs with more than 100 WHr capacity) to be subject to the regulations are classified as Class 9. This means they must be:
    • Packed by specially trained personnel
    • Using special packaging
    • With special documentation
    • Transported only by organisations with appropriate systems and training processes
  • Since the above list requires extra training, specially tested packaging and access to a limited number of suitably qualified carriers, significant extra cost is involved.
Tighter restrictions and even prohibition applies to transport by air.

Lithium batteries, whatever the classification, should never be sent by post.

Please ensure your supplier, and you, meet these regulations.

Conflict Minerals Policy

H-Squared supports the aims and objectives of the U.S. legislation on the supply of “conflict minerals”. A full policy statement is available below.

Modern Day Slavery and Human Trafficking

PURPOSE

To set out the Company Policy on Modern Day Slavery and Human Trafficking in the workplace and
ensure the communication of this policy to all employees within the company.

POLICY
1. The company acknowledges the provisions of the Modern Slavery Act 2015 and will
ensure transparency within its organisation and with suppliers of goods and services to the
organisation.

Modern slavery and human trafficking in all their various forms and guises are a crime in the
UK and much of the world. They are a violation of fundamental human rights.

The company will not tolerate or condone slavery or human trafficking in any part of our
organisation. We have a zero-tolerance approach to modern slavery and human trafficking
and are totally committed to acting ethically and with integrity in all activities and business
relationships and we expect our supply chain, contractors, employees and all other business
partners to commit to the same.

1.1 Imported goods from sources outside the UK and EU are potentially more at
risk of slavery and human trafficking issues therefore the level of
management control required for these sources should be continually monitored.

1.2 The company will not knowingly support or deal with any business involved in
slavery or human trafficking.

2. The Directors and senior management team at the Company have overall responsibility for
ensuring this policy complies with our legal and ethical obligations, and that all persons
working for us or on our behalf comply with it.

The prevention, detection and reporting of modern slavery in any part of our business or
supply chain is the responsibility of all persons working for us or on our behalf in any
capacity.

Management at all levels are responsible for ensuring those reporting to them understand
and comply with this policy.

3. The Company is satisfied from its own due diligence there is no evidence of any act of
modern day slavery or human trafficking within its own organisation.

As part of the Company’s due diligence processes into modern slavery and human trafficking
the supplier approval procedure incorporates a review of the controls undertaken by them.
The Company also conducts premises visits as deemed necessary to overseas suppliers to
ensure due diligence is observed.

Our Policy Statement is available to all employees and all employees are expected to read
and understand it. This policy must be clearly and prominently displayed on the Notice
Board at all business locations.

4. All persons working for us in any capacity must:

• Read, understand and comply with this policy, and avoid any activity that might lead
to, or suggest, a breach of this policy.
• Notify their immediate Manager as soon as possible if they believe or suspect that a
conflict with this policy has occurred, or may occur in the future. We have systems
in place for individuals to report concerns, anonymously if preferred, and to protect
whistleblowers.

5. The Company will review both its supply chain and internal operations on an annual basis to
check compliance with the above policy, and to ensure that our policy is being implemented
effectively.

The Directors and senior management team will review the Company’s statement in
response to any major business, organisational or legislative changes or as a result of any
breach or concern regarding modern slavery.

Approved by Steve Westbrook

Effective 22/11/19

Reach 2020

Re: EU REACH Regulation EC 1907/2006 and Substances of Very High Concern (SVHC)

Update: January 2020

We supply you with batteries, which under REACH, are treated as articles which are not intended to release substances. There are no obligations to register them or to provide Safety Data Sheets downstream. This said most battery manufacturers do provide Material Safety Data Sheets to meet other requirements that can be provided through links within our website (www.h-squared.co.uk) or on request.

All of the manufacturers that supply us have worked with their own suppliers to ensure the necessary registration of substances, where applicable, and the downstream provision of the relevant information (although as we say above, this is not currently required).

We can confirm that none of the products we supply you contain any of the substances in the latest update (January 2020) of the candidate list of Substances of Very High Concern above a concentration of 0.1% weight by weight.

I trust this is of assistance, however do not hesitate to contact us should you require further information.

Ian Ward – Logistics and Compliance Manager

For and on behalf of H-Squared (A Trading Division of UK Electric Ltd)

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