Compliance. Us and You.
I wanted to provide an update and break this down to make it a bit easier to digest for our customers while outlining the how and why of some changes being made to our service/products. Digesting the legislation even during a voluntary meeting with a representative from the EU Battery Directive and calling in a third party compliance advisor was like trying to swallow bad medicine. Unpleasant, but wholly necessary. I should point out to readers that this applies to EU/UK sales of cells ONLY. Much of this post will relate to wholesale clients, but retail customers should be aware of the changes being made.
How did this come about?
I attended a meeting along with another reputable company similar to ours with the UK Government Department for Business, Energy and Industrial Strategy this month. This was based on the use of the WEEE (Waste Electrical and Electronic Equipment Directive) bin logo that should be appearing on cells in compliance with The Restriction of Hazardous Substances Directive. This opened a can of worms we didn’t expect, given we were already working above and beyond the level the majority of battery/cell suppliers in the UK are in terms of batch testing, safety and quality of shipping. Complying with the WEEE regulations also means making a contribution to the collection and recycling of cells. This currently stands at around £1,300 for every ton of cells placed on the market. We hit this upto several times each month and not complying or paying for this has serious consequences.
What are the minimum requirements?
Based on the information from the above government representative and our compliance company, the minimum requirements for cell compliance when placed on the market are as follows;
- The WEEE Bin logo (min 5mmx12mm)
- Polarity ( + and – symbols)
- Capacity (mAh rating)
- Chemistry (Li-ion, for example)
Further to the above, we will also be putting the manufacturers maximum discharge rating displayed in Amps. We will likely also be putting unique serial numbers on the cells for full trace-ability. The marking must be indelible. You must not be able to pull, rub or otherwise easily remove the marking. This means (and in their owns words), that stickers on cells are “no longer good enough”, especially those annoying little white ones China seem to think are doing us a favour. There are three options. Re-wrap, laser-etch or print.
Do ALL cells have to be marked?
No. Only those being sold to end users must have these markings. Vape stores are covered in this though. If they are being built into accumulators/battery packs and the end product being sold, then the marking must be on the outside of the pack instead. The vast majority of our cells are sold wholesale to accumulator builders and so we’ve not been marking these. For those selling to end users, we have been offering a Retail Ready service with cell information on the box. This is no longer deemed sufficient for compliance but was looked upon favourably and was confirmed that cells wouldn’t be confiscated from stores but advice given.
I have cells that aren’t compliant, what do I do?
First of all, don’t panic. Almost all 18650 bare cell sales In the UK are currently non-compliant. We are only aware of one company who re-wrap cells for compliance. Others simply aren’t bothering/interested. An awareness of the legislation (for shop owners) will get you a long way with all but the worst that Trading Standards can offer in the way of their officers on a visit but the best thing to do is at least have them labelled. Until our new equipment is commissioned, we will be offering free labels to our wholesale customers. The reason they are non-compliant is on the basis that they are designed for use in battery packs but are being used individually in vaping so we have to make them compliant for individual sale.
How are 18650UK going to implement this?
We ruled out re-wrapping immediately. End users (especially those in the vaping industry) are normally (and often rightly) wary of re-wrapped cells, and the time and cost wouldn’t be economically viable with the number of cells we ship each month and would mean significant price increases. We initially considered laser-etch, however scale of economy rules this out too. We have opted for a Thermal Inkjet print system (A VideoJet 1560 for those interested in the technology!) which will sit on a conveyor in our packing process line and will mark around 2000-3000 cells an hour with instant drying and almost impossible to remove ink. Once our equipment is commissioned, ALL cells leaving us will have these extra markings on the factory wraps. The markings will look almost identical to factory markings. Again, for those interested, the cost of machinery/equipment to do this at a reasonable rate is in the region of £7000-£10,000. We are at the latter end of this scale based on the volume we need to process each day.
Will your prices increase?
No! Of the many reasons we chose the TIJ system, the best part is that despite the very expensive equipment, the processing effort is minimal and will have no impact on cell cost! What a time to be alive huh?!
My supplier isn’t providing this service, where do I stand?
If you are happy with the service and price you are getting, we would recommend putting pressure on them to be doing the above or at least getting the process started. It’s their duty by Law, whether they sell retail or wholesale. If they won’t, and you don’t have the facility/time to do so yourself, we would recommend switching to a company who does. While highly unlikely, its entirely possible for Trading Standards to simply confiscate non-compliant stock in stores and has happened on a handful of times to businesses in the UK.
I hope that the above proposed changes to the service serve to further prove our commitment to our clients both current and new in being at the front line of service delivery. As always, if this has generated any questions or you need any further information, please dont hesitate to get in touch by dropping us an email to firstname.lastname@example.org, or jumping on our Facebook page – www.facebook.com/18650uk
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Ben Mowbray – Sales Director – 18650UK