Position paper on labelling and information requirements in the new Batteries Regulation
Our suggestions to policy-makers[1]
| The duplication of information systems should be avoided to simplify the entire system and reduce the administrative burden and costs
a. The current proposal unnecessarily requires to provide similar information on the label, Battery Management System, QR code, Electronic Exchange System and Battery Passport |
The duplication of information systems should be avoided to simplify the entire system and reduce the administrative burden and costs
The current Batteries Regulation proposal includes several systems to store and communicate information, with clear overlaps. As it is now, the proposal requires information to be communicated though a label, the Battery Management System, a QR code, the Electronic Exchange System and the Battery Passport. Often, the information to be provided is the same: for instance, the date of manufacturing of the battery needs to be included in all these information systems.
It is difficult to understand why so many systems are needed, and why these duplications are included, in particular, the development of a QR code-linked database and the Battery Passport seem to be redundant. From the point of view of the industry, three systems should be developed, with clear demarcation lines regarding the information to be provided:
- A physical label, providing fundamental information on safety to the users and the recyclers;
- A battery management system for same batteries, including information on state of health to facilitate repurposing and repair;
- An online database, including general information on the battery, testing results and information for the end of life management.
- Information to be stored in the physical label
A physical label should of course be applied to the battery. An online database cannot replace a physical label: fundamental information on safety should be applied on the battery. However, since the space on the battery can be limited, we should carefully assess which kind of information needs to be included. In some cases, it could be preferable to move this information to the online database.
The type of information to be affixed on the physical label is listed in Article 13 and Annex VI. The following remarks should be considered:
- “The battery type, batch or serial number of the battery or other element allowing its unequivocal identification”: the “batch” is not defined in the text and should be removed, to streamline the process. In addition, the serial number will be required only for some battery types.
- “Date of placing on the market”: this type of information does not seem relevant. It is not a good indicator of the expected lifetime of the battery, since a battery can start its operations months or even years after being placed on the market. Besides, the manufacturer obviously does not know when the battery will be placed on the market if this is included in a product. Placing the label would therefore be quite challenging.
- The “chemistry” of the battery should be identified using the IEC Standard 62902 on color coding, where possible, to facilitate sorting and collection.
- “Hazardous substances contained in the battery other than mercury, cadmium or lead”. This type of information is already included in the SCIP, and it would be redundant to have it also on the label and in the QR code, also considering the effort made by the industry to comply with the SCIP. In addition, Article 13.4 already requires batteries to be marked with the symbol of lead or cadmium, and additional labels seem unnecessary. The detailed list of hazardous substances should be included in the online database through a cross-reference of the SCIP database.
- “Critical raw materials contained in the battery”. This type of information is only relevant for recyclers, not for consumers. It seems preferable to store it only in the online database (QR code or battery passport), not in the physical label. This would also allow updating the list.
In addition to the above and in line with the proposal, the physical label should report the manufacturer’s or producer’s name, registered trade name or trademark; the battery model identifier; date of manufacture; capacity label (for portable and automotive batteries); the separate collection symbol.
- Information to be stored in the battery management system
Article 14 and Annex VII regulate the information to be stored in the battery management system. Correctly, this information is related to the state of health and lifetime of the battery, and is relevant in view of the possible repurposing of the battery. The information included in Annex VII seem to be relevant, therefore we do not have particular problems with it.
However, Article 14.1 requires all rechargeable industrial batteries and electric vehicle batteries with internal storage and a capacity above 2 kWh to have a BMS. This is a clear indication that the proposal was developed considering only the specificities of one type of battery: lithium and sodium batteries are equipped with a BMS, while lead and nickel batteries generally do not need such system to be managed. Requiring them to be equipped with a BMS is therefore totally unnecessary, also considering that generally, these batteries are not suitable for second life applications, and it would result in waste of resources and in a clear market distortion. Therefore, we strongly suggest that only batteries equipped with a BMS should store this kind of information.
For batteries equipped with a BMS, clearer rules on access to data should be formulated. This article cannot result in a blank cheque for any party to access the BMS. Granting such access would endanger safety and intellectual property. For this reason, only the information listed in Annex VII should be accessible.
- Information to be stored in the online database
The major problem with the proposal is related to the duplication of the QR code, Electronic Exchange System and Battery Passport. In some cases, the information to be stored in the systems is repeated: points (a) to (h) of Annex XIII are exactly the same as listed in Annex VI, and there is no point in reporting the same information in two databases.
Considering that the Battery Passport could be developed internationally, the preferred solution might be to develop this system and to make it accessible through a machine-readable format, as suggested in Article 64. A completely separate QR-code system would be evidently redundant.
The type of information to be included should be based on those listed in Annex XIII, with some modifications. Points (i) to (r) of Annex XIII should be only accessible to the actor who purchased the battery. In addition, point 2.a of Annex XIII requires the disclosure of the detailed composition of the battery, including materials used in the cathode, anode and electrolyte. Providing this information would clearly go against the need to protect intellectual property. Besides, this point is already covered by point 1.e on battery composition: general information on the type of materials used is sufficient for recycling purposes.
Finally, a major limit of the system is that it does not allow tracking the information related to second life batteries. A second life battery requires a new filing into the system, which does not necessarily include its status or a link to the first life battery passport.
[1] With this position paper, EUROBAT would like to provide its position on the proposal on labelling and information requirements, as described in Articles 13-14, 64-65, Annex VI-VII-XIII of the Proposal for a Regulation 2020/353 concerning batteries and waste batteries.