85061000
ELECTRICAL MACHINERY AND EQUIPMENT AND PARTS THEREOF; SOUND RECORDERS AND REPRODUCERS, TELEVISION IMAGE AND SOUND RECORDERS AND REPRODUCERS, AND PARTS AND ACCESSORIES OF SUCH ARTICLES›Primary cells and primary batteries
Manganese dioxide
Subcodes (4)
Scope of subheading 850610 - manganese dioxide primary cells/batteries
Subheading 850610 covers primary (disposable) cells and batteries with manganese dioxide depolariser. Includes alkaline (zinc-manganese alkaline) and zinc-carbon (Leclanche) batteries. Alkaline batteries are the most widely used consumer batteries in AA, AAA, C, D and 9V (6LR61) formats. Zinc-carbon batteries are cheaper but lower capacity. Cells are single electrochemical units; batteries are assembled packs. Classification requires manganese dioxide as cathodic depolariser. Lithium batteries under 850650. Classification per GRI 1 and 6.
Regulatory requirements - Battery Regulation
Import subject to Regulation (EU) 2023/1542 (Battery Regulation), replacing Directive 2006/66/EC. Requirements: minimum recycled content, hazardous substance limits (mercury, cadmium, lead), crossed-out bin symbol labelling, collection/recycling obligations, carbon footprint declaration (from 2027 for portable batteries above threshold). RoHS 2 applies. CE marking required. CBAM does not apply.
Customs duties and trade
MFN rates should be verified in TARIC. Alkaline and zinc-carbon batteries imported in volume from China. Major brands: Duracell, Energizer, Panasonic, Varta. Disposable battery market gradually declining vs rechargeable, but alkaline remains dominant in consumer use. Preferential rates under FTAs require rules of origin. VAT charged on import.
EU Battery Regulation and batteries under 8506 10
Primary batteries under CN 8506 10 are subject to the EU Battery Regulation (EU) 2023/1542. From 18 February 2027, portable batteries must meet requirements for minimum recycled content, labelling and a battery passport. Mercury oxide batteries are banned in the EU. MFN duty: 4.7%. Import requires registration in the national battery producer registry. WEEE obligations also apply.
Frequently asked questions
What requirements does Battery Regulation impose on manganese batteries?
Regulation (EU) 2023/1542 requires: crossed-out bin symbol labelling with capacity information, mercury limit (below 0.0005% by weight) and cadmium limit (below 0.002%), used battery collection system, recycling/recovery targets, carbon footprint declaration (planned from 2027), battery passport (for industrial and EV batteries). The importer is responsible for compliance.
Do alkaline AA/AAA batteries require CE marking?
Yes. Alkaline batteries as electrical products are subject to LVD (2014/35/EU) for safety and require CE marking. The manufacturer must issue an EU declaration of conformity. Batteries must also meet Battery Regulation labelling and recycling requirements. IEC 60086 defines technical requirements for primary batteries.
Are manganese batteries subject to CBAM?
No. CBAM covers: steel, aluminium, cement, fertilisers, electricity and hydrogen. Batteries from Chapter 85 are not within CBAM scope.
What Battery Regulation requirements apply to 8506 10?
Batteries under 8506 10 are subject to (EU) 2023/1542: labelling, minimum recycled content from 2027, producer registration, and battery passport. Mercury batteries are banned.
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