Safe Collection and Transport of Electronic Equipment with Lithium Batteries
Lithium batteries present particular challenges during the collection, transport, storage and recycling of waste electrical and electronic equipment. EERA developed this Technical Guidance to help operators understand the ADR requirements applying to the carriage of WEEE containing lithium cells and batteries.
The guidance explains the circumstances in which ADR restrictions apply, the exemptions available for certain equipment, and the requirements for packaging, labelling, transport and quality assurance. It focuses in particular on the provisions introduced for the carriage of WEEE containing lithium batteries under Special Provision 670.
Lithium batteries and ADR requirements
Lithium cells and batteries are classified as dangerous goods and their carriage is regulated under ADR, the European agreement governing the international carriage of dangerous goods by road. Because lithium batteries are increasingly incorporated into electrical and electronic equipment, these requirements also affect the collection and transport of WEEE.
From 2019, Special Provision 670 (SP 670) introduced specific provisions for the collection and carriage of WEEE containing lithium batteries from private households. For the purposes of the provision, this also includes equipment from commercial, industrial, institutional and other sources where its nature and quantity are similar to household equipment. Dual-use equipment is also treated as equipment from private households. The guidance distinguishes between equipment that can be transported exempt from the ADR restrictions covered by the document and equipment for which the restrictions apply.
When WEEE is exempt from ADR restrictions
According to the guidance, the ADR restrictions covered by the document do not apply to equipment from private households that does not contain lithium cells or batteries, or where the lithium batteries have been removed before transport.
The exemption also covers equipment where lithium cells or batteries are present but are not the main source of power, provided the conditions identified in the guidance are met. Examples include appliances containing button cells for memory functions and computers or other equipment where the main battery pack has been removed.
For the exemption to apply, the guidance specifies that:
Lithium cells and batteries must not be the main power source for operation of the equipment
The equipment must not contain another lithium cell or battery serving as its main power source
Exempt lithium cells and batteries must be protected by the equipment itself
There must be no loose lithium batteries.
The guidance indicates that no specific ADR labelling or additional ADR requirements apply to this exempt category. It also allows bulk carriage of small appliances and tight-fit loading or other means of securing larger appliances.
When ADR restrictions apply
The guidance distinguishes between large equipment and other types of WEEE where lithium cells or batteries are the main source of power.
For large household equipment containing lithium cells or batteries as the main power supply, the equipment may be carried on pallets or loosely packed where the equipment itself provides protection for the batteries and there is no risk of losing the equipment, cells or batteries during carriage.
For other WEEE containing lithium cells or batteries as the main source of power, the guidance identifies examples including small appliances, household and kitchen equipment, tools, toys and IT equipment. Different packaging requirements apply to this category.
Packaging and transport requirements
For WEEE subject to the relevant ADR restrictions, equipment must be packed in accordance with Packaging Instruction P909 or in strong outer packaging, such as specially designed collection receptacles.
The guidance specifies that such packaging should:
be constructed from suitable material and have adequate strength and design;
prevent loss of contents during carriage, for example through lids, strong inner liners or covers;
include measures to minimise damage to equipment during filling and handling, such as rubber mats; and
not exceed 400 kg net weight or 3 m³per package.
For this category of WEEE, bulk transport is not permitted. The guidance specifies packaging such as boxes, cases or barrels within the stated weight and volume limits and identifies a limit of less than 333 kg of lithium cells per vehicle.
Labelling and quality assurance
Where ADR restrictions apply, packages must be labelled “Lithium Batteries for Disposal” or “Lithium Batteries for Recycling”.
For large equipment carried unpackaged or on pallets, the guidance allows the label to be placed on the external surface of the vehicle or container.
A quality assurance system must also be in place to ensure that transport units do not exceed 333 kg of lithium cells or batteries. For equipment from private households, the total quantity may be assessed using a statistical method incorporated into the quality assurance system.
Quality assurance records must be made available to competent authorities on request. The guidance also advises operators to retain records of sample loads.
About this guidance
This Technical Guidance was published in 2019 and reflects the ADR provisions applicable at the time of publication. Readers should refer to the current ADR requirements when determining applicable transport obligations.
Read the full technical guidance
Access the original EERA Technical Guidance, including the detailed ADR requirements for different categories of WEEE containing lithium cells and batteries.
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