Understanding the Updated Requirements
Batteries play a crucial role in our transition to a greener future, but they also contain materials that are at risk of depletion. To address this, the European Commission has revised its legislation on batteries to promote a more sustainable, circular approach. This updated regulation affects both companies that introduce batteries and battery-powered products into the market. Link to the new ligislation here.
The European Commission, the European Parliament, and member states have agreed on a new regulation that imposes requirements on batteries throughout their entire lifecycle. This regulation is directly applicable across all EU member states without needing transposition into national laws.
Circular Product Requirements Introduced
The new regulation includes demands for the durability and performance of batteries, sets minimum recycled content requirements, and mandates that by 2027, end-users must be able to easily remove and replace portable batteries in devices. Additionally, it upholds traditional environmental standards, such as limits on mercury and cadmium content, which are crucial for recycling and reusing materials.
Supply Chain Due Diligence
The regulation mandates companies to perform due diligence within their supply chains and prove that the sourcing of raw materials is sustainable and respects human rights throughout the production process.
Digital Battery Passport
For the first time, the regulation requires a digital battery passport to enhance the traceability of batteries and their materials, facilitating recycling and reuse. Although this is a new concept with limited current knowledge on its practical application, several pilot projects are underway. Expected information in the passport includes identification details (e.g., QR code or RFID tag), technical specifications, environmental impact data, social compliance information, economic details, and lifecycle data.
Changes in Producer Responsibility for Batteries
Existing extended producer responsibility (EPR) for batteries means producers are already required to finance the collection and waste management of batteries at the end of their life. The new regulation sets ambitious targets for battery collection and material recycling, shifting the responsibility for achieving these targets from member states to producers.
Traditionally municipalities have been responsible for collecting household batteries. However, under the new regulation, this responsibility may no longer fall to municipalities, suggesting a need for agreements between producers and municipalities if this collection method is to continue.
Effective Date and Implementation
The regulation is effective from August 2023, but many requirements will be phased in over the coming years. For example, requirements for CO2 footprint and minimum recycled content are set to begin in mid-2025.
CO2 Footprint Calculation Method
The regulation adopts the Product Environmental Footprint (PEF) method for calculating the CO2 footprint.
Scope of Batteries Covered
The regulation applies to all batteries, including spent portable batteries, electric vehicle batteries, industrial batteries, starter batteries, and batteries for light means of transport (e.g., electric bicycles, mopeds, and scooters).
Collection Targets
The regulation sets collection targets for portable batteries (63% by the end of 2027 and 73% by the end of 2030) and spent batteries for light means of transport (51% by the end of 2028 and 61% by the end of 2031).