The crossed-out wheeled bin symbol

Different EU legislation for different waste streams

Significant waste streams are generated by the disposal of the ever-increasing amount of electrical and electronic equipment (EEE) and batteries. To reduce harm to health and the environment from the release of hazardous substances, EU legislation restricts the use of hazardous substances in EEE at the manufacturing stage. At the same time, this reduces potential exposure to hazardous substances during the use phase, where exposure can occur through dermal contact, oral ingestion, and inhalation. Further major waste streams are batteries, end-of-life vehicles and packaging for which separate EU legislation on hazardous substances has been enacted.

The end-user must be instructed via appropriate product labelling and instructions to dispose of such products separately from unsorted municipal waste at special collection and return points. If the product contains one-way batteries or rechargeable batteries that are not permanently installed, these must be removed before disposing of the product and be disposed of separately as batteries. Electrical and electronic equipment that can be operated wholly or partially with batteries or accumulators must therefore be designed in such a way that used batteries and accumulators can be removed easily and non-destructively by end users. At a minimum, it must be possible to remove them easily and non-destructively by independent specialist personnel of the manufacturer using commercially available tools.

The correct marking therefore depends primarily on which product is being disposed of via which waste stream. Both electrical and electronic equipment and batteries are marked with the symbol of a crossed-out wheeled bin but this is based on two different legal bases and with different specifications for the correct representation.

Is the article an EEE or a battery?

Often it is unclear which marking is correct for the article in relation to the crossed-out wheeled bin. The main issue is whether the crossed-out wheeled bin is displayed with or without a bar. Both symbols serve the purpose of informing the consumer about proper disposal. The legal definition of the article is therefore essential. It is crucial whether the item is an EEE or a battery. The legal basis for this definition and decision is the respective European harmonisation regulation, within the scope of which the article falls.

Marking on electrical and electronic equipment (EEE)

The key EU harmonisation rule is the WEEE Directive 2012/19/EU on waste electrical and electronic equipment. To minimise unsorted waste from WEEE and to facilitate separate collection, manufacturers must label EEE placed on the market in accordance with the European standard EN 50419 and the bin symbol specified therein (Annex IX):

• According to Article 15 (2) of the WEEE Directive and Clause 4.1 b) of EN 50419:2006 at least one of the following two options shall be applied to indicate that the equipment is put on the market after 13 August 2005:
  • An additional mark being a black bar as shown in the figure above.
  • The date of manufacture / put on the market, in un-coded text in accordance with ISO 8601 or other coded text. The date may be a separate individual marking and does not need to be placed close the crossed-out wheeled bin.
• The marking shall be visible, legible, and indelible on the product. If the marking cannot be on the product due to size or its function, then the marking shall be on the packaging, in the instructions for use and in the warranty of the EEE.
• The symbol shall have a minimum height of 7 mm (a = 3,33 mm).
• The black bar shall be at least 1 mm (0,3 a).

There is a 2022 edition available of the EN 50419 standard. Compared to EN 50419:2006 there are the following changes due to EN 50419:2022:

• EN 50419:2006 still refers to the old WEEE Directive 2002/96/EC and the corresponding labelling requirements. EN 50419:2022 defines the labeling requirements regardless of the version of the directive or regulation.
• EN 50419:2022 describes in more detail the combined representation of the crossed-out wheeled bin with the black bar and/or the date of manufacture, and a separate representation of the crossed-out wheeled bin and the date of manufacture.

The symbol and design requirements will not change. The fact that the black bar indicates that the EEE was made available on the market after 13 August 2005 does not change either. 

Definition of EEE

In the meaning of the WEEE Directive 2012/19/EU, Article 3(1): Electrical and Electronic Equipment or ‘EEE’ means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1.000 volts for alternating current and 1.500 volts for direct current.

The RoHS Directive 2011/65/EU has the same definition for an EEE as the WEEE Directive and lays down rules for the restriction of the use of hazardous substances in EEE in order to contribute to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE. Recital 14 specifically states that RoHS should apply without prejudice to the Batteries Directive. Recital 29 of the Batteries Directive 2006/66/EC states RoHS does not apply to batteries and accumulators used in electrical and electronic equipment.

Marking on batteries

The key EU harmonisation rule is the Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators. The crossed-out wheeled bin according to Annex II shall indicate “separate collection” for all batteries and accumulators to minimize the negative impact on the environment:

Battery with more than 0,0005 % mercury (Hg)

Battery with more than 0,002 % cadmium (Cd)