85065000
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
Lithium
Subcodes (3)
Scope of subheading 850650
Subheading 850650 covers primary (disposable) lithium cells and batteries. Not to be confused with rechargeable lithium-ion accumulators (heading 8507). Primary lithium batteries are disposable energy sources at 3V (Li-MnO2) or 3.6V (Li-SOCl2). Applications: CR2032, CR2025, CR123A in remote controls, IoT devices, smoke detectors, medical devices and military systems. Li-SOCl2 used in metering (10–20 year life). Classification requires lithium anode and disposable nature. Rechargeable Li-ion = heading 8507. Classification per GRI 1 and 6.
Regulatory requirements
Subject to Battery Regulation (EU) 2023/1542. Lithium batteries are Class 9 dangerous goods under IATA DGR and ADR (UN3090/UN3091). Packaging, labelling and transport documentation must meet dangerous goods requirements. Lithium coin cells (CR2032) require child-resistant packaging from 2025. RoHS 2 applies. CE marking required. CBAM does not apply.
Customs duties and trade
MFN rates should be verified in TARIC. Imported mainly from China, Japan and South Korea. Market growing dynamically with IoT, sensing and automation. CR2032 is the most traded format. Preferential rates under FTAs require rules of origin. VAT charged on import.
EU Battery Regulation and batteries under 8506 50
Primary batteries under CN 8506 50 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
How do primary lithium batteries (850650) differ from Li-ion accumulators (8507)?
Primary lithium batteries under 850650 are disposable (non-rechargeable) with metallic lithium anode, e.g. CR2032 (3V). Li-ion accumulators under heading 8507 are rechargeable with lithium ions migrating between electrodes (e.g. 18650, pouch cells). Key criterion: disposable = 850650, rechargeable = 8507. Correct classification matters due to different duty rates and regulations.
What transport requirements apply to lithium batteries?
Lithium batteries are Class 9 dangerous goods (UN3090 - lithium metal, UN3091 - in equipment). Air transport subject to IATA DGR, road transport to ADR. Requirements: special packaging, warning labels, transport documentation (Shipper's Declaration), quantity limits per shipment. Non-compliance risks refusal and penalties.
Are primary lithium 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 50?
Batteries under 8506 50 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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