China Battery Hazardous Substance Restriction Standard (GB 24427-2021)
ENFORCEMENT TIMELINE
Effective November 1, 2021
Overview
GB 24427-2021, "Limitation of Mercury, Cadmium and Lead Content in Zinc-Manganese Dioxide, Zinc-Silver Oxide, Zinc-Air and Alkaline Batteries," is a mandatory national standard issued by China's State Administration for Market Regulation (SAMR) and the Standardization Administration of China (SAC). It consolidates and revises the earlier GB 24427-2009 and GB 24428-2009 standards, setting strict maximum limits on mercury (Hg), cadmium (Cd), and lead (Pb) content in primary batteries — including button cells and cylindrical dry cells — manufactured, sold, or imported in China. The standard particularly tightens "mercury-free" requirements for button batteries, aiming to prevent environmental pollution and align with the Minamata Convention on Mercury.
Enforcement Timeline
- April 30, 2021: SAC formally issued GB 24427-2021.
- November 1, 2021: GB 24427-2021 took mandatory effect, replacing the earlier GB 24427-2009 and GB 24428-2009 standards.
- After November 2021: Market regulators and customs authorities began conducting spot checks and import inspections.
Business Impact
- Battery manufacturers and importers: Companies producing or exporting primary batteries (dry cells, button cells) for the Chinese market must meet the heavy-metal content thresholds set out in GB 24427-2021 (e.g., mercury ≤0.0001%, cadmium ≤0.002%, lead between 0.004% and 0.1% depending on battery type) to clear customs and sell in China.
- Equipment manufacturers (OEMs): Companies embedding batteries in electronics, toys, watches, medical devices, or remote controls exported to China must confirm that the batteries used carry GB 24427 certification or a compliant test report.
- Labeling and certification obligations: Companies must comply with environmental labeling requirements such as "mercury-free" markings on batteries and packaging, and maintain a conformity assessment system.