G/TBT/N/SGP/23  
 
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  Attachment 1  
 
Proposed Tightening of Controls  for Mercury -added Batteries and 
Button Cell Batteries in Singapore  
 
 
Introduction  
 
The Nati onal Environment Agency (NEA) of Singapore is carrying out a 
public consultation on a plan to  phase out the use of mercury -added1 batteries 
(including button cell batteries) containing more than 5ppm mercury (by 
weight) per cell.  The phase -out would mean that companies cannot 
manufacture, import and export mercury -added batteries (including button cell 
batteries) in Singapore by 2018 .  
 
Background  
 
2 The Minamata Convention on Mercury (Convention) is a global, legally 
binding instrument that seeks “to pro tect human health and the environment 
from anthropogenic emissions and releases of mercury and mercury 
compounds.”  Singapore signed on to the Minamata Convention on 10 Oct 
2013 to demonstrate our commitment to safeguard the environment. A set of 
domestic control measures are being put in place to meet the obligations of the Convention (e.g.   control and reduction in emissions and releases on 
mercury, control on trading of mercury for allowable uses, control of mercury -
added products ).  The full list of mercury -added product s to be controlled 
under the convention is shown  in Annex 1.  
 
Rationale for tightening the control for Mercury -added Batteries and 
Button Cell Batteries  
 
3 Batteries are common power sources that are used to power up a wide 
range of port able devices which are commonly found in households (e.g. 
clock, toy, radio  etc.). It can also come in the form of button cells which are  
used for small devices such as calculators, hearing aids  and watches (refer to 
Annex 2 for types of controlled batteri es). In order to ensure the durability of 
these products, mercury is used to inhibit corrosion;  otherwise corrosion in 
batteries can lead to gas build -up, and eventually physical bulging and 
leakage, or it can limit battery function.  
 
                                                
1 Mercury -added product refers to a product that contains mercury or a mercury compound that was intentionally added 
for any reason.  G/TBT/N/SGP/23  
 
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  4 The Minamata Conv ention requires the manufacture, import or export of 
all mercury-added batteries to be phased out by 2020.   This is with the 
exception of button zinc silver oxide batteries and button zinc air batteries with 
mercury content of less than 2% which are exclud ed from the 2020 phase -out 
schedule under the Convention.  
 
5Currently, under NEA’s Environmental Protection and Management Act (EPMA), Singapore prohibits the import of zinc-carbon batteries containing more than 10ppm of mercury (by weight) per cell, alk aline batteries containing 
more than 250ppm mercury (by weight) per cell and mercury oxide batteries 
for local sale. All button cell batteries are exempted under the EPMA.  The 
controls measures under the Minamata Convention are more stringent than 
NEA’s c urrent requirements.  
  
6 With technolog ical advancement, the methodology  for manufacturing 
mercury -free batter ies is well established. M any major producers are already 
making the transition toward s manufacturing mercury -free batteries in 
response to mark et demand and government policies. Mercury -free 
alternatives are therefore available.  
 7The cost impact on manufacturers and consumers is expected to be reduced 
over time as production systems and manufacturing technology improve with economies of scale , due to increasing demand for mercury -free batteries 
worldwide.   
 
1.1.  Scope of Control  
 
8 In aligning NEA’s  proposed controls with the provisions of the Minamata 
Convention, NEA will adopt the list of exemptions under Annex A of the 
Minamata Convention (refer  to Annex 1 of REACH Document for 
exemptions). NEA will also extend the scope of control measures to include all 
mercury -added button cell batteries . 
1.2.   
9Following  a market survey and industry consultation on the  type of mercury -
added batteries  being sold and traded in Singapore, NEA plans to enhance 
the existing controls for mercury-added batteries to include button cell 
batteries, and to phase out all batteries that contain mercury exceeding 5ppm 
mercury (by weight) per cell by restricting the manufacture, import and export 
of all non -compliant mercury -added batteries (including button cell batteries) in 
Singapore by 2018, ahead of the phase -out date of 2020 specified in the 
Minamata Convention.  G/TBT/N/SGP/23  
 
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Key Features of Proposed Control for Batteries in Singapore  
 
10 The mercury limits for batter ies that are proposed for control in 
Singapore are aligned with the current limits stipulated in the European 
Battery Directive  (refer to Annex 3  for EU Directive 2013/56/EU) where the 
following are not allowed to be place d on the market : 
 
(a) All batteries or accumulators  that contain > 5ppm  mercury (by weight ); 
 
(b) All button cells with >  5ppm mercury (by weight ). 
 
Transitional Provisions  
 
11 NEA plans to publish the gazette on  the revised controls that would be 
covered under t he EPMA in  the 1st half 2017.   NEA would allow for a one-
year grace period after the gazette to provide battery importers, 
manufacturers, distributors and retailers time to clear their existing stocks of batter ies and to meet contractual agreements ; comply  with the requirements 
set forth ; and for suppliers to source alternatives manufacturers.  
 
12 With effect from 1
st Quarter 2018, the import , manufacture and export  of 
non-compliant batteries  in Singapore would be prohibited. The effective  date 
for i) locally manufactured  electronic and electrical equipment  (EEE) to be sold 
in Singapore would be the date  of manufacture ; and ii) imported EEE to be 
sold in Singapore would be the date  of import . Batteries  that are supplied in 
the market before the effective implementation date will be allowed for local 
sale till stocks are depleted.  
  
Compliance and Testing  
 
13 For stand -alone batteries imported into Singapore,  manufacturers 
/importers /distributors must declare the battery conformity  at import /export 
stage wi th NEA and produce test reports of the mercury content of the 
batter ies to demonstrate compliance with the proposed mercury limits and 
quality standards. Test reports from one of the following categories of testing 
laboratories will be accepted:  
 
a) Manufactu rer’s in-house testing laboratories,  
 
b) Testing laboratories in countries other than Singapore that are 
accredited by their local accreditation bodies, which have signed a 
Mutual Recognition Arrangement with the Singapore Accreditation Council (SAC), to carry out the test in accordance with the applicable 
test standards, or  G/TBT/N/SGP/23  
 
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c) Testing laboratories that are accredited by the SAC to carry out the 
test in accordance with the applicable test standards.  
 
14 For products bundled with batteries in the same packaging, NEA will 
harmonise the compliance approach with the EU ’s approach , where 
companies are required to show proof of compliance upon request by the 
authority.  
 
15 Non-compliant batteries are not allowed to be sold in Singapore . The 
batter ies placed on the mar ket must be compliant with Singapore’s 
requirements. As part of our enforcement process, NEA conducts market 
surveillance  to test scheduled products for compliance . If a product is 
suspected to be non -compliant, NEA may request for the 
manufacturer/trader’ s declaration of conformity and test reports. NEA may 
also send the product for testing.  Companies that are found guilty may be 
subject to product withdrawal and penalty.  
 
 Moving Forward 
 
16 In accordance with our obligations to the Minamata Convention, NEA will 
extend restrictions  on mercury content to other five categories of products 
containing mercury, such as lightings, switches and relays etc., that are listed 
in the convention for phase -out by 2020, and will regularly review the 
relevance of such l imits. 
 
 
 
 
 
* * * 
 
 
 
 
 
 ANNEX 1  
 
List of restrictions on 
Mercury Added produ     
 
 
 
 
 
 G/TBT/N/SGP/23  
 
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  ANNEX 2  
 
Type  Images  Current Controls  Minamata 
Controls  Proposed 
Enhanced 
Controls  
Zinc-
Carbon  
(Zn-C) 
 The following 
Mercury -added 
batteries (except in 
button form) are 
already pr ohibited for 
import for local sales:  
• Alkaline > 
0.025% 
(250ppm) by 
weight in 
weight per 
cell 
• Zinc -
Carbon > 
0.001% 
(10ppm) by 
weight in 
weight per 
cell 
• Mercury 
Oxide 
batteries  All 
batteries (including Alkaline 
and 
Mercuric 
oxide button 
cells) are 
to be 
mercury -
free 
 
Exemption  
Button 
zinc silver 
oxide and 
zinc air 
batteries with < 2% mercury 
are 
exempted 
from 
control  To prohibit the 
import for local sale 
of all batteries, 
including all button 
cells, of > 5ppm  
mercury (by weight) 
per cell by 1Q2018.  
Alkalin e 
 
Mercury 
Oxide  
 
Zinc 
Silver 
Oxide  
 No controls  
Zinc Air  
 No controls  
 
 ANNEX 3  
Eu batteries directive 
2013.pdf