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EU Battery Regulation
1. EU Battery-Related Regulatory Directives
On September 26, 2006, the Battery and Accumulator and Waste Battery Directive 2006/66/EC was promulgated, which came into effect on September 26, 2008, primarily targeting battery production and end-of-life recycling.
On December 10, 2013, the EU officially issued the new directive 2013/56/EU, amending the Battery Directive 2006/66/EC. The new directive came into effect on July 1, 2015.
On December 10, 2020, the EU officially released the "Proposal for a New Battery Regulation," intending to repeal the original EU Battery Directive. Key stakeholders, including the European Parliament, the EU Council, and the European Economic and Social Committee, proposed and issued revised opinions. On March 10, 2022, the "EU Battery and Waste Battery Regulation" (hereinafter referred to as the "New Battery Law") was voted through in the European Parliament (plenary session), with modifications and additions based on the "Proposal for a New Battery Regulation."
2. Regulated Batteries
The "New Battery Law" categorizes batteries into five types: portable batteries, automotive batteries, industrial batteries, electric vehicle traction batteries, and light means of transport batteries. All batteries entering the EU market must comply with this regulation.
3. Interpretation of the New Regulations
The "New Battery Law" covers all stages of the battery lifecycle and introduces "new" requirements in many aspects:
First, "new" in carbon footprint requirements. The "New Battery Law" requires light means of transport batteries and electric vehicle batteries with an internal storage capacity exceeding 2 kWh, as well as rechargeable industrial batteries, to calculate the carbon footprint of the product's production cycle. Those failing to meet the relevant carbon footprint requirements will be prohibited from entering the EU market. The carbon footprint requirements are implemented in phases: first, disclosure of information, preparing a carbon footprint declaration based on delegated acts; second, grading, clearly labeling the corresponding carbon footprint performance level on the battery; and finally, setting mandatory limits, requiring technical documentation to prove that the declared lifecycle carbon footprint value is below the maximum lifecycle carbon footprint threshold set by the EU.
Second, "new" in requirements for each stage of the battery lifecycle.
(1) In the production stage, the requirements mainly focus on battery sustainability and safety, as well as labeling and information. Regarding battery sustainability and safety, the "New Battery Law" requires:
① Limiting the content of toxic and hazardous substances;
② Specific carbon footprint requirements for certain batteries;
③ Batteries must meet certain electrochemical performance and durability standards, with non-rechargeable batteries being phased out gradually in the future;
④ Use of recycled raw materials, and requirements for the removability and replaceability of portable batteries.
Regarding battery labeling and information, the regulation requires manufacturers to specify prescribed information on battery labels to facilitate use and recycling by end-users.
For traction batteries, which are of particular concern to the automotive industry, the battery label should include basic information (manufacturer information, battery type, etc.), capacity information, the separate collection symbol, and chemical symbols for substances exceeding limits. For traction batteries with an internal storage capacity greater than 2 kWh, a battery management system should also be included, containing data on battery health status and expected lifespan parameters. Additionally, traction batteries should have a QR code label for accessing relevant information.
(2) In the quality control stage, battery manufacturers must conduct conformity assessments according to prescribed procedures, with carbon footprint, recycled raw material content, and supply chain due diligence requiring verification by qualified institutions.
(3) In the management stage, market entities (battery manufacturers, importers, distributors) are obligated to develop supply chain due diligence plans to assess and mitigate risks related to raw material sourcing.
(4) In the end-of-life recycling stage, battery manufacturers should organize the collection, transportation, and recycling of waste batteries at their own expense. The law also sets minimum recycling targets and proposes that the EU will gradually increase these targets as recycling technology advances.
Third, "new" in battery information and market management requirements.
To facilitate battery information traceability and strengthen oversight, the EU has decided to establish a battery lifecycle information traceability platform by January 1, 2026. This platform will include information on rechargeable industrial batteries and electric vehicle batteries with an internal storage capacity greater than 2 kWh, with three levels of access: public, market entities, and market supervision authorities. The regulation also outlines EU market supervision processes, battery control and safeguard procedures, and requires contracting authorities and entities to procure low-carbon batteries, fostering a favorable low-carbon battery market environment within the Union.
Compared to the original "Battery Directive," the "New Battery Law" features more detailed battery classifications, more production requirements, higher targets, and more complex responsibility requirements, aiming to drive the green and low-carbon transformation of the battery industry with stricter standards.
4. Regulated Substances
Currently, the Battery Directive regulates three hazardous substances: lead, cadmium, and mercury. The regulatory details are as follows:
Prohibition of production and sale of batteries or accumulators with a mercury content exceeding 5 ppm.
Prohibition of production and sale of portable batteries or accumulators with a cadmium content exceeding 20 ppm (exempt products: emergency and alarm systems, including emergency lighting and medical equipment).
Batteries or accumulators containing lead exceeding 40 ppm should be labeled with the chemical symbol of the corresponding metal: Pb.
5. Labeling Requirements
All batteries and accumulators should bear the crossed-out wheeled bin symbol.
If batteries or accumulators meet the following conditions: cadmium content > 20 ppm or lead content > 40 ppm, they must be labeled as shown in the figure below, with the symbol of the element indicated.
The Battery Directive also specifies clear requirements for label dimensions, with the chemical symbol occupying at least one-quarter of the area of the crossed-out wheeled bin symbol. In principle, the label should be placed on the battery itself. If space is limited, it may be placed on the packaging, and the battery itself does not need to be labeled.
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