Mercury Regulation (EU) 2017/852: Industrial Restrictions and Obligations.
Regulation (EU) 2017/852 implements the Minamata Convention and sets a comprehensive framework for mercury: export ban, import controls, prohibition of mercury-added products, safe storage of surplus mercury, and waste management obligations. IgeraIndustria answers every compliance question: which products are prohibited, storage requirements, traceability obligations, and the dental amalgam phase-out timeline.
Mercury Regulation: export bans, product prohibitions and storage obligations
Companies in the chlor-alkali, lighting, measurement instruments, and waste sectors face multiple obligations under the Mercury Regulation: product prohibitions with phase-out dates, export and import bans, surplus mercury storage requirements, and waste traceability. Many companies do not have a clear picture of which provisions apply to their activities.
Total export ban
on metallic mercury, mercury compounds and mixtures with concentration above thresholds. Export ban applied since 2011 (extended from 2008 Regulation). No exceptions for mercury placed on market.
Minamata 2017
EU acceded to the Minamata Convention on Mercury in 2017. Regulation 2017/852 implements EU obligations including the Annex A product prohibitions and Annex B process controls.
Amalgam ban 2025
dental amalgam use banned from 1 January 2025 under the 2024 amendment to Regulation 2017/852, with limited exceptions for specific medical cases.
Regulatory and EHS teams in affected sectors spend hours determining which products fall under Annex I prohibitions, what storage conditions apply to surplus chlor-alkali mercury, and what traceability documentation is required for mercury waste. IgeraIndustria answers those questions in seconds, citing the exact Regulation article or Annex entry, so teams can focus on compliance implementation rather than regulatory interpretation.
Instant Mercury Regulation query by product category and obligation
IgeraIndustria locates the exact Mercury Regulation prohibition, storage requirement or reporting obligation that applies to each question and responds with the applicable Annex entry and phase-out date.
Mercury-added product prohibition scope
Annex I lists prohibited mercury-added products with prohibition dates. IgeraIndustria identifies whether a specific product falls within Annex I scope, applies the correct prohibition date, and clarifies any limited exemptions that may apply (e.g. measurement instruments for industrial processes).
Chlor-alkali mercury surplus storage
Article 11 requires surplus mercury from chlor-alkali plant decommissioning to be stored in compliance with specific technical conditions. IgeraIndustria clarifies the storage facility requirements, the prohibition on placing surplus mercury on the market, and the notification obligations to competent authorities.
Mercury export and import controls
Article 3 prohibits export of metallic mercury, cinnabar ore, mercury compounds above specified concentrations, and mercury-added products listed in Annex I. IgeraIndustria maps which substances and products are covered by the export ban and the limited exceptions for laboratory use or disposal purposes.
Dental amalgam phase-out obligations
The 2024 amendment to Regulation 2017/852 banned dental amalgam from 1 January 2025 with limited medical exceptions. IgeraIndustria identifies the remaining permitted uses, the obligations for dental practitioners to manage amalgam waste, and the transition period conditions for stock management.
Mercury waste management
Mercury-containing waste must be managed as hazardous waste under Directive 2008/98/EC. IgeraIndustria clarifies which mercury waste streams require specific pre-treatment before disposal, the prohibition on diluting mercury waste to reduce concentration below hazardous thresholds, and the storage time limits.
Minamata Convention obligations for traders
EU companies exporting mercury compounds not prohibited under Annex I must comply with prior informed consent procedures under the Minamata Convention. IgeraIndustria maps which compounds require PIC procedures, the importing country notification requirements, and the annual reporting obligations to the Commission.
Complete Mercury Regulation compliance support
From product scope assessment to surplus storage management and waste traceability, IgeraIndustria supports the regulatory and EHS team at every stage of Mercury Regulation compliance.
Product Annex I prohibition assessment
IgeraIndustria identifies which of your products contain mercury above de minimis thresholds and whether they appear in Annex I with their prohibition date. For products not in Annex I, it identifies whether they fall under the general prohibition on manufacturing mercury-added products not listed as allowed.
Chlor-alkali decommissioning compliance
Mercury from chlor-alkali plant conversion must be managed under Article 11. IgeraIndustria maps the obligations for plant operators: storage facility certification, prohibition on placing mercury on the market or exporting it, and the documentation required for the Commission triennial monitoring report.
Mercury compound export documentation
Certain mercury compounds can be exported for specific uses but require Minamata Convention PIC procedures. IgeraIndustria identifies which compounds require PIC, the documentation that must accompany export shipments, and the consent confirmation requirements from importing country authorities.
Mercury waste classification and tracking
Mercury waste must be classified under the European Waste Catalogue (EWC codes 16 08 xx for spent catalysts; 20 01 21 for fluorescent tubes). IgeraIndustria clarifies applicable EWC codes, the pre-acceptance requirements for hazardous waste facilities, and the traceability documentation chain from generation to final disposal.
Dental sector amalgam transition
Dental practitioners had to stop using amalgam by 1 January 2025. IgeraIndustria clarifies the remaining permitted emergency use exceptions, the waste amalgam management obligations (amalgam separators under ISO 11143), and the documentation requirements for demonstrating compliance to national authorities.
Triennial reporting obligations
Member States report mercury supply and demand data to the Commission every 3 years. Large mercury operators must contribute data to national reports. IgeraIndustria identifies which operators have reporting obligations, the data elements required (quantities, origins, destinations), and the submission format expected by national environmental authorities.
4 core obligations of Mercury Regulation (EU) 2017/852
These obligations define what industrial companies, traders and waste operators must implement to comply with the Mercury Regulation.
Export ban — mercury and mercury-added products
Article 3 prohibits export of: metallic mercury (Hg), mercury (I) chloride (calomel), mercury (II) oxide, mercury (II) sulphate, mercury (II) nitrate, cinnabar, and mixtures with mercury concentration ≥95% by weight. Export of mercury-added products listed in Annex I is also prohibited as of their respective prohibition dates. Exceptions are narrow: laboratory reagents, disposal to authorised facilities in non-EU countries under strict conditions.
Annex I product prohibitions — manufacturing and import
Article 4 prohibits manufacturing, use, import and export of mercury-added products listed in Annex I as of their respective phase-out dates. The 2024 amendment added dental amalgam (banned from 2025). Companies must audit their product portfolio against the current Annex I list including phase-out dates and any exemptions for specific professional or industrial uses that may apply.
Surplus mercury storage — chlor-alkali and other sources
Article 11 addresses temporary storage of mercury surplus from chlor-alkali decommissioning, natural gas purification and mining operations. The surplus cannot be placed on the EU market or exported. It must be stored in dedicated facilities meeting technical conditions: mercury in steel containers, leak detection, covered storage, temperature controls. The Commission has published technical guidelines for compliant storage facilities.
Mercury waste — hazardous waste obligations and traceability
Article 12 classifies mercury waste as hazardous waste under Directive 2008/98/EC. Mercury waste cannot be mixed with non-hazardous waste. Solidification or stabilisation before disposal in deep geological formations is the preferred treatment route. A full chain of custody documentation is required from generation to final disposal. The prohibition on dilution to avoid hazardous classification (Article 18 Waste Framework Directive) applies strictly.
How IgeraIndustria works for Mercury Regulation (EU) 2017/852
Five steps from loading your product and substance documentation to receiving an answer with the exact Regulation article, Annex entry, and traceability requirement.
Index your mercury compliance documentation
Upload your product specifications, substance inventory, existing export documentation, waste management records, and mercury storage records. IgeraIndustria processes them together with the full Mercury Regulation 2017/852 text and Minamata Convention annexes in under 24 hours.
Connect the assistant to your regulatory team
Embed it in your compliance management system, Teams, Slack or as a standalone tool for the regulatory and EHS team. One line of code. Compatible with any document management system.
Ask in plain language
«Can we export mercury (II) chloride for laboratory use?», «Does our mercury storage facility meet Article 11 requirements?», «What EWC code applies to our amalgam waste?»
IgeraIndustria searches across 2 knowledge layers
First in your internal product, storage and waste documentation, then in the indexed Mercury Regulation 2017/852, Minamata Convention annexes, and Commission technical storage guidelines.
Answer with Regulation article, Annex entry and traceability requirement
The response cites the applicable Regulation article or Annex I product entry, states the prohibition date or storage condition, and flags the most common compliance gaps that national environmental authorities identify during mercury facility inspections.
IgeraIndustria in action — chlor-alkali mercury surplus storage query
Mercury surplus storage obligation after chlor-alkali decommissioning resolved in under 3 seconds with the applicable Article 11 conditions and notification requirements.
Environmental Compliance Manager
We converted our chlor-alkali plant from mercury cells to membrane technology and have 45 tonnes of surplus metallic mercury. Can we sell it or export it, and how must we store it in the meantime?
IgeraIndustria
Mercury Regulation (EU) 2017/852 — Art. 11 Chlor-Alkali Surplus
What you CANNOT do:
- • Place the 45 tonnes on the EU market — prohibited under Art. 11(1)
- • Export it — prohibited under Art. 3 (mercury export ban applies to all metallic mercury)
Storage requirements (Art. 11 + Commission storage guidelines):
- • Store in certified steel flasks or containers; leak detection required
- • Covered, temperature-controlled storage facility
- • Notify competent authority of quantities, origin and storage location
⚠️ Long-term: final disposal in deep geological formations is the only legally compliant permanent solution. Contact MINCOTUR (Spain) for authorised disposal facilities.
✓ Mercury Regulation (EU) 2017/852 Art. 3 + Art. 11 · Confidence: 99.2%
490
employees, specialty chemicals
-65%
mercury compliance research time
0
export violations since implementation
We trade mercury compounds for laboratory and industrial applications across 12 countries. Determining which compounds can be exported under Minamata PIC procedures versus which fall under the total export ban took our team days per shipment. IgeraIndustria gives us the answer in seconds with the exact Article reference. No export violations since implementation and our documentation package for every shipment is now audit-ready from the start.
*Representative testimonial based on results from real customers
Frequently asked questions — Mercury Regulation (EU) 2017/852
Which mercury-added products are prohibited under Regulation (EU) 2017/852?
Annex I of the Mercury Regulation lists products prohibited from manufacturing, import and export (with phase-out dates): mercury thermometers for non-industrial use (prohibited since 2009 under previous law), sphygmomanometers for non-industrial use, skin-lightening cosmetics containing mercury, pesticides and biocides with mercury, batteries (except button cells ≤2% mercury), compact fluorescent lamps for general lighting purposes ≥30W (prohibited from 2020), general purpose linear fluorescent lamps (various dates), high-pressure mercury vapour lamps (prohibited from 2015), and dental amalgam (phase-out by 2025 under the 2024 amendment).
How must excess mercury from industrial processes be stored?
Mercury surplus arising from the chlor-alkali industry, natural gas purification, non-ferrous mining or smelting operations, or surplus from dental amalgam recycling cannot be placed on the market or exported. It must be stored temporarily in certified safe storage facilities complying with Article 11 of the Regulation and the requirements of storage guidelines issued by the Commission. Permanent safe storage in deep geological formations is the long-term objective. Spain must designate or certify storage facilities meeting the technical requirements for temporary storage pending permanent disposal.
What traceability and reporting obligations apply to mercury traders?
Companies that trade in metallic mercury or mercury compounds must comply with information requirements under Articles 6–8 of the Regulation. Exporters need prior informed consent procedures for mercury compounds not prohibited but subject to Article 3 of the Minamata Convention. Mercury waste must be managed as hazardous waste under Directive 2008/98/EC with full traceability. The Commission publishes a triennial report on mercury supply and demand in the EU, drawing on data reported by Member States. Large-scale mercury storage operators must notify competent authorities of quantities, origin and planned final destination.
IgeraIndustria Mercury Regulation Plans
No lock-in. Cancel whenever you want.
Starter
For regulatory teams that need to identify mercury product prohibitions and export restrictions without months of Regulation research.
- Mercury Regulation 2017/852 pre-indexed
- Annex I product prohibition checker
- Export ban scope identification
- 1,000 queries/month
- Widget for the regulatory team
- Email support
Professional
For companies with mercury trade, storage or waste management obligations that need ongoing Mercury Regulation compliance support.
- Regulation + internal compliance docs indexed
- Mercury storage facility assessment
- Waste traceability documentation
- 5,000 queries/month
- Regulatory amendment alerts
- Priority support
Enterprise
For industrial groups with mercury surplus storage, multi-country trade or chlor-alkali decommissioning requiring integrated compliance management.
- Multi-site mercury compliance management
- Minamata PIC procedure support
- Triennial reporting preparation
- Unlimited queries
- 99.9% uptime SLA
- Dedicated customer success
Comply with Mercury Regulation 2017/852. Zero export violations.
- Free 14-day trial — no credit card required
- Full Mercury Regulation (EU) 2017/852 and Minamata Convention pre-indexed from day 1
- Upload your product inventory, export documentation and storage records
- Annex I prohibition checker and mercury waste traceability guidance