EU Declaration of Conformity
Regulation (EU) 2023/1542
1. Product Identification
| Product: | Li-MnO₂ Button Cell (non-rechargeable) |
| Battery Category: | Portable battery for general use |
| Model Number: | CR1620 |
| Batch Number: | Refer to battery body or PO No. & Packing Label |
2. Object of the Declaration
This declaration covers the following product:
Li-MnO₂ Button Cell (non-rechargeable)
| Model: | CR1620 |
| Chemistry System: | Li-MnO₂ |
| Nominal Voltage: | 3.0V |
| Nominal Capacity: | 70mAh |
| Category: | Portable battery for general use (sealed, ≤ 5 kg) |
| Battery Type: | Primary (non-rechargeable) |
The battery is identifiable by the model number "CR1620" printed on the negative electrode of each battery cell and on the product packaging. The batch number is traceable via the battery body or Purchase Order (PO) number and packing label.
For complete technical specifications, performance data, markings, and safety information, please refer to the Battery Information Page .
3. Manufacturer
| Manufacturer Name: | Shuyang Xinneng Battery Co., Ltd. |
| Address: | No. 1, Industrial Concentration Zone, Hanshan Town, Shuyang County, Suqian City, Jiangsu Province, China |
| Postal Code: | 223600 |
| Website: | www.xnbattery.com |
| Email: | xn_d@xinnengdianchi.com |
4. Authorized Representative
| Representative: | Synertrade FR SAS |
| Address: | 9 rue du Bat d'Argent,69001 Lyon,Franc |
| Contact Person: | Sophie Bennett |
| Postal Code: | 69001 |
| Email: | info@syner-sarl.cn |
| Tel: | +33 774555006 |
5. Conformity
We, Shuyang Xinneng Battery Co., Ltd., declare under our sole responsibility that the above-mentioned products comply with the applicable requirements of the following legislation:
Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC.
Conformity has been assessed by demonstrating that the products comply with the following technical specifications, standards and/or legislation.
6. Applicable Standards
| IEC 60086-1:2021 | Primary batteries — Part 1: General |
| IEC 60086-2:2021 | Primary batteries — Part 2: Physical and Electrical Specification |
| IEC 60086-3:2021 | Primary batteries — Part 3: Watch batteries |
| IEC 60086-4:2025 | Primary batteries — Part 4: Safety of lithium batteries |
7. Conformity Assessment
Procedure: Module A — Internal Production Control
The conformity assessment procedure applied is Module A — Internal Production Control as described in Annex VIII of Regulation (EU) 2023/1542. Under this procedure, the manufacturer assumes full responsibility for ensuring that the battery complies with all applicable requirements of the Regulation. The manufacturer keeps the technical documentation and the EU Declaration of Conformity available for inspection by national authorities for a period of 10 years after the last battery of this model has been placed on the market.
Notified Body: Not Applicable
Not Applicable — Module A (Internal Production Control) does not require the involvement of a Notified Body.
8. Substance RestrictionsCompliant
This product complies with the heavy metal concentration limits set out in Annex I of EU Regulation (EU) 2023/1542:
| Mercury (Hg): | ≤ 0.0005% by weight |
| Cadmium (Cd): | ≤ 0.002% by weight (portable batteries only) |
| Lead (Pb): | ≤ 0.01% by weight (portable batteries only; zinc-air button cells exempt until 18 August 2028) |
This product complies with the applicable restrictions of REACH Regulation (EC) 1907/2006, Annex XVII.
This product complies with the EU POPs Regulation (EU) 2019/1021.
Testing is performed in accordance with the IEC 62321 series of standards.
SVHC Information Disclosure (REACH Article 33)
The electrolyte of this product contains ethylene glycol dimethyl ether (EGDME, CAS 110-71-4) above 0.1% w/w, a substance included in the REACH Candidate List of Substances of Very High Concern (SVHC). EGDME is an essential component of lithium battery electrolytes, and no viable alternative is currently available. This information enables downstream users to fulfil their information obligations under Article 33 of the REACH Regulation.
For the complete Hazardous Substances Statement, see the Battery Information Page — Hazardous Substances .
9. Additional Regulatory Articles
Article 7 — Carbon footprint declaration Not yet applicable
The delegated act establishing carbon footprint calculation rules for portable batteries of general use has not yet been published under Regulation (EU) 2023/1542. This requirement is currently not enforceable for this battery category.
Article 8 — Recycled content in batteries Not yet applicable
The delegated act establishing minimum percentages of recycled content for portable batteries of general use has not yet been published. This requirement is currently not enforceable for this battery category.
Article 11 — Removability and replaceability of portable batteries Not yet applicable
This battery is supplied independently as a lithium manganese dioxide button cell and is not installed in equipment by the manufacturer. The removability and replaceability requirements of Article 11 apply to portable batteries incorporated into equipment and therefore do not apply to this product.
Articles 48–52 — Supply chain due diligence obligations Not yet applicable
The due diligence requirements in Chapter VII of the Regulation apply only to economic operators with annual net turnover exceeding EUR 40 million. Shuyang Xinneng Battery Co., Ltd. has not reached that threshold at the time this declaration is issued.
Annex III — Performance and durability requirements Not yet applicable
The performance and durability requirements for portable batteries of general use in Annex III will apply from 18 August 2028. In addition, Annex III expressly excludes button cells from the scope of electrochemical performance and durability requirements. For reference, the performance characteristics of this battery (capacity, minimum average duration, and specific application test results) are available on the battery information page.
Directive 2014/30/EU — Electromagnetic compatibility (EMC) Not yet applicable
This battery is a passive primary (non-rechargeable) lithium manganese dioxide button cell and contains no active electronic components, integrated circuits, or battery management system. As it has no electronic switching or signal processing, EMC Directive 2014/30/EU does not apply to this product.
Battery management systems (BMS) Not yet applicable
This product is a passive primary (non-rechargeable) lithium manganese dioxide button cell and contains no electronic components, circuits, battery management system, or communication interface. The provisions and requirements of the Regulation concerning batteries equipped with BMS or active electronics do not apply to this product.
10. CE Marking & Labelling
The following markings are printed on the battery body and/or packaging in accordance with Article 13 and Annex VI of Regulation (EU) 2023/1542:
- CE marking — Indicates compliance with all applicable EU health, safety and environmental protection requirements (Articles 19–20).
- Separate collection symbol (crossed-out wheeled bin) — In accordance with Article 13 and Part B of Annex VI, indicates that the battery must not be disposed of with unsorted household waste.
- Chemical symbols "Cd" and "Pb" (if the thresholds are exceeded) — This model does not exceed the limits, so these markings are not required.
- "Keep out of reach of children" symbol — In accordance with Article 13, warns of the risk of ingestion, particularly by young children.
- "Do not recharge" symbol — Indicates that this product is a non-rechargeable (primary) battery; recharging may cause leakage, fire or explosion.
- Model identification "CR1620" — Printed on the battery body.
- Manufacturer identification "XINNEY / No-brand / OEM brands" — Printed on the battery body.
- Production date code (year-month format) — Printed on the battery body.
- Nominal voltage (3.0V) — Printed on the battery body.
For complete marking and labelling details, see the "Marking" section of the Battery Information Page .
Signatures
Signed for and on behalf of:
Shuyang Xinneng Battery Co., Ltd.
| Place: | Shuyang, Jiangsu, China |
| Date: | 2026-08-15 |
| Name: | Li Dong |
| Position: | Chairman |
Signed for and on behalf of:
Synertrade FR SAS
| Place: | Lyon, France |
| Date: | 2026-08-15 |
| Name: | Sophie Bennett |
| Position: | Authorized Representative |
