After all, the EU Battery and Waste Battery Regulation (hereinafter referred to as the EU Battery Law) came into force on August 17 after a long wait. The core point of the 537 pages of documents is one sentence: who produces who recyles, who imports who recyles. The European Union is a car consuming region that is making a steady transition to electric vehicles. The entry into force of the EU Battery Law will have a profound impact on the development of the global power battery industry.Recently, Chinese power battery companies have "gone to Europe." Industry insiders call on the current Chinese power battery companies to enhance their competitiveness in sustainable development as soon as possible, as well as build information disclosure capabilities based on battery passports.
Eu perspective
The preceding section of the EU Battery Law sets out the background and reasons for the legislation, as well as the process of legislation, in 143 articles, clarifying the EU's view.The European Green Deal (" European Green Deal ") is Europe's growth strategy that aims to transform the EU into a fair and prosperous society, a modern, resource-efficient and competitive economy with no net greenhouse gas emissions by 2050 and with economic growth decoupled from resource use. Switching from fossil fuels in cars to electric vehicles is one of the prerequisites for achieving climate neutrality by 2050. In order for the EU's product policies to contribute to reducing carbon emissions globally, it is necessary to ensure that products marketed and sold in the EU are sourced and manufactured in a sustainable way. This is the original intention of the EU Battery Law legislation.Directive 2006/66/EC of the European Parliament and of the Council improves the environmental performance of batteries and lays down a number of common rules and obligations for economic operators, in particular by harmonizing the rules for the heavy metal content and labelling of batteries and the rules and objectives for the management of all waste batteries, based on the extension of producer responsibility.The EU Battery Act distinguishes between portable batteries and industrial batteries, etc. The Act stipulates that any battery weighing more than 5kg that does not fall into any other category under this Regulation shall be considered an industrial battery. Batteries used for energy storage in private or domestic environments should be considered industrial batteries. Batteries used for traction of wheeled vehicles shall, for the purposes of this Regulation, not be regarded as LMT batteries, but as portable batteries.The above part of the full life cycle carbon footprint, rare element recycling, mining and other guidelines have been elaborated, laying the foundation for the later battery legal provisions.
Carbon footprint, what is it? The EU Battery Law specifies that the carbon footprint refers to the sum of greenhouse gas emissions and greenhouse gas removals in a product system, expressed in carbon dioxide equivalent and based on a product environmental footprint study using the single impact category of climate change. In short, it is how much carbon dioxide equivalent there is in the production and use process of the battery, as well as the later recycling treatment. Add raw material information requirements to the declaration documents to cover the share of renewable materials; The announcement of the maximum carbon footprint threshold has been advanced from July 1, 2026 to January 1, 2026.How is the carbon footprint calculated? This is a matter of concern to everyone. The EU Battery Law requires the calculation of the "climate change" life cycle impact assessment methodology recommended in the 2019 Joint Research Centre report entitled "Recommendations for updating the Product Environmental Footprint (PEF) Methodology".In setting the maximum life-cycle carbon footprint threshold referred to in subparagraph 1, the Commission shall take into account the relative distribution of the carbon footprint values of batteries on the market, the extent of progress made in reducing the carbon footprint of batteries on the market, and, And the actual and potential contribution of these life-cycle carbon footprint thresholds to the EU's goals of sustainable mobility and climate neutrality by 2050. This rule means that the maximum carbon threshold is open to negotiation.The EU Battery Law has a percentage requirement for the metal elements to be recovered from batteries, a minimum percentage share of cobalt, lithium or nickel to be recovered from battery manufacturing waste or post-consumer waste, and a minimum percentage percentage of lead present in batteries: 16% cobalt; 85% lead; 6% lithium; Six percent nickel.The battery contains a minimum percentage share of cobalt, lithium or nickel recovered from battery manufacturing waste or post-consumer waste in the active material, respectively, and a minimum percentage share of lead present in and recovered from waste per battery model per year and per manufacturing plant: 26% cobalt; 85% lead; 12% lithium; 15% nickel.The EU Battery Law specifies battery labelling, marking and information requirements, and non-rechargeable portable batteries shall bear a label containing information on the minimum average duration when used in a particular application and a label indicating "non-rechargeable".All batteries shall be marked with the battery separate collection symbol shown in Part B of Annex VI (" Separate Collection Symbol "). Individual collection symbols should cover at least 3% of the maximum side area of the battery, with a maximum size of 5×5cm. In the case of cylindrical batteries, a single collection symbol should cover at least 1.5% of the battery's surface area and the maximum size should be 5 x 5cm. If the size of the battery makes the individual collection symbol less than 0.47×0.47cm, the battery does not need to be marked with that symbol. Instead, a separate collection symbol with a size of at least 1×1cm should be printed on the package.All batteries containing more than 0.002% cadmium or more than 0.004% lead should be marked with the chemical symbol of the relevant metal: Cd or Pb. The relevant chemical symbol indicating heavy metal content should be printed below a separate collection symbol and should cover an area at least one-quarter the size of that symbol.The EU Battery Law provides more specific provisions on liability, and the economic operator who provides the battery to the market for the first time in the territory of the Member State shall be regarded as the producer of the battery and shall bear the extended producer responsibility. Producers, in the case of individual performance of extended producer responsibility obligations, as well as designated producer responsibility organizations in the case of collective performance of extended producer responsibility obligations, shall apply to the competent authority for extended producer responsibility authorization.There is a new term "battery passport" in the EU Battery Law, and the information in the battery passport should include: information available to the public; Information only available to notified bodies, market supervisory bodies and committees; Information only available to any natural or legal person with a legitimate interest in obtaining and processing the information.Of particular concern is a provision in the restriction procedure which provides that if a Member State considers that a substance is present in a battery that poses a risk to human health or the environment and is not adequately controlled when it is used in the manufacture of the battery, or at the time the battery is placed on the market, or at subsequent stages of its life cycle, including during the reuse or disposal of waste batteries, Where a Union-wide solution is required, the agency shall be notified of the proposed restriction file. Member States shall prepare a restriction dossier. The restriction file should include a socio-economic assessment and an analysis of alternatives.The EU Battery Law gives clear regulations on restricted substances. Whether contained in electrical appliances, light transport vehicles or other vehicles, the mercury content (expressed as mercury metal) must not exceed 0.0005%; Cadmium content (expressed as cadmium metal) shall not exceed 0.002%; Lead content must not exceed 0.01%.
Challenges to China's battery exports and local production
As a global new energy vehicle country, China has formulated relevant policies and regulations before the introduction of the EU Battery Law. On February 26, 2018, the Chinese government website announced on the issuance of the Interim Measures for the Management of the Recycling and Utilization of New Energy Vehicle Power Batteries (referred to as the "China Battery Management Measures"), which are different from the management measures of the EU Battery Law.Liang Rui, vice president of Xinwang Da, told reporters that the main responsibility of battery recycling in China is automobile production enterprises; The responsibility for battery recycling in the EU Battery Law can be battery companies, or importers or vehicle manufacturers that put batteries into the EU market. China and the European Union also have different requirements for the responsibility of the responsible body. The "China Battery Management Measures" requires automobile manufacturers to establish recycling service outlets, responsible for collecting waste power batteries, centralized storage and transfer to the relevant enterprises in cooperation with their agreements. The EU Battery Law requires responsible parties to designate a producer responsibility organization, which will review the access of battery recycling and processing enterprises.China's new energy vehicle export trend is good, Europe is the main market, but the measures of the "EU battery Law" and "China's battery management measures" have a big difference, which involves the issue of mutual certification. True lithium research CEO Mo Ke told reporters that after the "EU battery Law" came into effect, Europe will inevitably emerge a number of identification institutions, the use of these institutions is very different from the domestic, the future of China's new energy vehicles and batteries exported to Europe will have a lot of problems, such as, "China's battery management measures" is relatively extensive, "EU battery Law" is relatively fine, The existing approach is more difficult to adapt to the requirements of the EU Battery Law.Liang Rui also believes that the "EU battery Law" has a greater impact on China's new energy vehicles and battery exports. The EU Battery Law has put forward clear requirements on sustainability issues such as carbon footprint, battery recycling, use of recycled materials, and due diligence, and the performance of sustainable development has changed from a plus point for enterprises to a veto. He told reporters, "The current global power battery companies in these areas are in the initial stage of exploration, Chinese companies need to establish relevant capabilities as soon as possible, in the next stage of competition to gain an advantage."Another key requirement in the EU Battery Law is that power battery companies need to disclose basic information, sustainable development information and use information of batteries through battery passports. The disclosure of information may cause the leakage of core data such as technology and supply chain. Chinese enterprises need to build an autonomous, controllable and secure battery passport platform for data collection, collation and interaction." Liang Rui said.Moke also mentioned that the EU Battery Law encourages foreign companies to set up production and recycling enterprises in Europe, and local production reduces costs and meets local requirements to increase production and employment. European battery recycling generally uses fire recovery, China mostly uses wet recovery, wet recovery of the production chain is relatively long, and a large number of acid and alkali liquids, which puts forward higher requirements for the environmental protection of enterprises.Liang Rui believes that the EU Battery Law puts forward clear requirements for battery recycling, technical and environmental standards for battery recycling enterprises, and the use of recycled materials. When Chinese battery companies invest in the EU to build factories, supporting battery recycling and processing enterprises that meet the requirements of the EU will become an inevitable choice. Supporting battery recycling and processing enterprises, building a battery recycling system can solve the difficulties of recycling batteries as the main body of battery recycling on the one hand, and ensure the source of recycled materials on the other hand.At present, China Auto Data led the launch of the "power battery sustainable Development action Plan", one of the tasks is to study the feasibility of landing the Chinese version of the battery passport.The implementation of the Chinese version of the battery passport, the automotive and battery industry has two ideas, one is the domestic battery system and international standards; The other is to treat the export and non-export power batteries differently. Standard for export batteries to connect to the European Battery passport; Non-export battery manufacturers continue to improve the traceability management of battery life cycle according to the requirements of domestic laws and regulations.
