01 what is the EU's New Battery Law? What?
In July 2023, the EU officially published the new Battery Regulation (EU)2023/1542, entitled Regulation 1542 of the European Parliament and of the Council on Batteries and Waste Batteries. This is the first legal document on battery life cycle management in the form of regulations, covering all stages of battery production, use, reuse and recycling. The new battery law aims to implement more comprehensive supervision of the entire battery industry chain to ensure that all batteries in the EU market (including stand-alone batteries and batteries embedded in final products such as electrical and electronic equipment and vehicles) are sustainable, high-performance and high-safety throughout their entire life cycle, while reducing the impact of batteries on the environment and society. The regulation aims to promote the development of the battery industry in a more sustainable and environmentally friendly direction, and to ensure that the production, use and recycling of batteries meet strict compliance requirements.
The New Battery Act A series of requirements were put forward, including banned substances, carbon footprint, sustainability and safety, labeling, due diligence, battery passport and used battery management. At the same time, the regulation details the responsibilities and obligations of manufacturers, importers and distributors of batteries and products containing batteries, and establishes conformity assessment procedures and market supervision requirements.
In addition, the Regulation amends the EU Waste Directive 2008/98/EC and the Market Regulation (EU) Regulation 2019/1020, and repeals the Primary Battery Directive 2006/66/EC. The regulations will enter into force on August 17, 2023.
02 the New Battery Act five types of batteries will be clearly included in the regulation
the control objects stipulated in the EU's "New Battery Law" include portable batteries, starting batteries, automotive batteries (SLI batteries), light transport vehicle (LMT) batteries, power batteries and industrial batteries. The control objects also have clear requirements and regulations.
1. Portable battery: batteries not specially designed for industrial use, sealed and weighing no more than 5kg, not belonging to electric vehicle batteries, LMT batteries or SLI batteries.
2. Starting, lighting, ignition battery (SLI battery): batteries used for vehicle ignition, lighting or starting purposes, or auxiliary or backup batteries on vehicles, other transportation or mechanical transportation equipment.
3. Electric vehicle battery: batteries that provide power for L-type hybrid or pure electric vehicles and weigh more than 25kg, and batteries that provide power for M, N, and O-type hybrid or pure electric vehicles.
4, light Vehicle Battery (LMT Battery): battery sealed and weighing not more than 25kg, powering wheeled vehicles (including category L).
5. Industrial batteries: batteries designed for industrial use or intended for industrial use after reuse, or other batteries weighing more than 5kg that are not electric vehicle batteries, LMT batteries or SLI batteries.
03 Detailed requirements for sustainability and safety of five types of batteries included in the regulation:
1. Requirements for prohibited substances:
must comply REACH Regulation (EC/1907/2006) prohibited substance requirements listed in Annex XVII. In addition, the requirements for prohibited substances in Article 4(2) (a) of the EU Vehicle End-of-Life Directive (2000/53/EC) must be met. The new battery regulations require no more than 0.0005 percent mercury in all batteries, 0.002 percent cadmium in portable batteries (except for emergency and medical use), and 0.01 percent lead in portable batteries.
2. Carbon footprint requirements:
for electric vehicle batteries, LMT batteries and rechargeable industrial batteries (capacity greater than 2KWh), the carbon footprint requirements need to be gradually met, and there is a detailed implementation period. The specific carbon footprint calculation should be based on the basic elements provided in Annex II of the new battery regulation and comply with the requirements of the latest version of the EU Product Environmental Footprint (PEF) Method and Product Environmental Footprint Category Rules (PEFCRS).
3. Recycling requirements:
from August 18, 2028 onwards, for electric vehicle batteries, SLI batteries and rechargeable industrial batteries (above 2KWh) containing cobalt, lead, lithium, nickel and other active materials, the attached technical documents shall contain information on the percentage of cobalt, lithium and nickel in the active materials and recovery information, and the percentage of lead content in the battery and recovery information.
From August 18, 2031 onwards, the proportion of cobalt, lead, lithium and nickel recovered from the waste of active materials of various manufacturers and types of batteries shall not be less than 16% of cobalt, 85% of lead, 6% of lithium and 6% of nickel. From August 18, 2036 onwards, it shall not be less than 26% of cobalt, 85% of lead, 12% of lithium and 15% of nickel.
4. Electrochemical performance and durability requirements:
from August 18, 2024, electric vehicle batteries, rechargeable industrial batteries (2KWh or more), LMT batteries are required to be accompanied by technical documents containing electrochemical performance and durability parameters.
5. Removable and replaceable:
all portable batteries should have a removable battery design that allows consumers to remove, remove or replace the battery without the use of special tools (such as solvents, heat) or training. All LMT batteries should be easily removed and replaced by professionals.
6. Safety:
for stationary battery energy storage systems, starting from August 18, 2024, their safety during operation should be proved in the attached technical documents.
04 Included in the regulation of five types of batteries of labeling, Marking and Information Requirements:
1. General information: from August 18, 2026 onwards, all batteries should be affixed with the manufacturer's information, battery type, chemical composition and other harmful substances other than lead, cadmium and mercury, key raw materials and other 10 items of content label;
2. Capacity information: from August 18, 2026, rechargeable portable batteries, LMT batteries and SLI batteries shall be labeled with capacity information, and non-rechargeable portable batteries shall also be marked with the minimum average continuous discharge time and marked "non-rechargeable";
3. Separate collection of symbols: from August 18, 2025, all batteries should be affixed with a separate collection symbol. As shown below, batteries with a cadmium content of more than 0.002% or a lead content of more than 0.004% should be added with the corresponding chemical element symbol under the "trash can mark": Cd or Pb;
4. Two-dimensional code: from February 18, 2027, all batteries shall be accompanied by a QR code.
05 digital battery passport:
from February 18, 2027, LMT batteries, industrial batteries with a capacity greater than 2kwh and electric vehicle batteries placed on the market or put into use should have an electronic record, that is, a digital passport.
The digital passport can be linked to different information for different people. It is mainly divided into four parts: publicly accessible information; Open only to persons with legitimate interests and the Commission; Information accessible only to certification bodies, market surveillance authorities and the Commission; Information and data accessible only to persons with legitimate interests.
06 the New Battery Act the impact:
in the short term, the implementation of the "battery passport" will bring some pressure to China's battery enterprises.
Although my country has an earlier layout in the battery field, it has formed a relatively complete industrial chain, and has initially established a power battery recycling policy system based on the basic principle of the extended producer responsibility system. However, compared with the European Union and other developed economies, China's battery carbon footprint accounting and methodology is still weak, power battery carbon emission management is still facing unclear policies, standard database is not unified, international mutual recognition is not open, lack of enterprise power and other challenges. Due to the complexity of the information involved in the digital "battery passport" and carbon footprint, and the lack of digital tools in the supply chain, it is not easy to implement.
In order to meet the new EU battery regulations, the carbon cost of China's battery industry may increase, resulting in a weakening of the original competitive advantage. Chinese battery companies may also face compliance risks due to the complexity of battery passports when exporting products to the EU.
In the long term," "Battery Passport" the implementation can promote China's battery enterprises to speed up the improvement recycling, carbon footprint, digital passport and other initiatives to transition the management object from the use phase of carbon emissions to the whole industry chain carbon emissions, thereby enhancing product lifecycle carbon management capabilities.
