The extraction and processing of raw materials is responsible for half of all greenhouse gases globally. These are necessary for the linear model of our economy that has been established for decades. Earth’s resources are extracted, processed into products, and soon afterward discarded. As a result, a significant amount of resources is simply lost. Improving these conditions would have a major, positive impact on our environment. This is especially true for batteries, which often contain rare metals.
Two new sets of legislation are intended to contribute to a more sustainable use of these resources. The European Union’s Ecodesign for Sustainable Products Regulation (ESPR) and EU’s Regulation (EU) 2023/1542 attempt to combat this problem. With the ESPR and Regulation 2023/1542, a framework for the ecodesign requirements of certain products has been created. The goal is to save resources and energy through a circular economy. Among other things, a digital passport shall be introduced (to provide more transparency). Every product that falls under the Regulation 2023/1542 and the ESPR is supposed to be marked. This makes tracking and identification possible. Data on sustainability and product lifecycle are, thus, ideally visible to every participant in the supply chain, right through to the end customer. Furthermore, the impact on manufacturers is difficult to assess at present but will present the market with major challenges.
Regulation 2023/1542 – The New Battery Law
With Regulation 2023/1542, the European Union implemented a new set of rules for the market placement of batteries. It amends Directive 2008/98/EC and Regulation (EU) 2019/1020, and repeals Directive 2006/66/EC. The new regulation is intended to regulate the marketing, return, and disposal of batteries and accumulators (rechargeable batteries). It is irrelevant whether the batteries are permanently installed in devices or not.
The new regulation also defines the take-back of offered batteries. Furthermore, the legislation requires batteries to be labeled from August 18, 2026, an exact instruction to the labeling format is not given. However, this labeling is to be represented by a QR code from February 18, 2027. Within the new battery law, the track-and-trace system is called a battery passport.
Implications for Manufacturers
On the one hand, the new regulations are a crucial step towards sustainability. On the other hand, they represent a disruption in the market. Considering the extent of the regulations and the products affected, it quickly becomes evident that manufacturers will face overwhelming challenges. Companies that have had little contact with European regulations to date are particularly affected. Every cordless screwdriver, every electric toothbrush, and every electronic lighter will have to be labeled. Manufacturers may have to employ additional staff for these purposes. For small and medium-sized companies, this can result in a critical additional burden. Therefore, it is essential to deal with the BattG2 promptly.
What Does the Battery Pass Say?
The battery passport should contain a wide range of information. In total, the label contains 28 points. This includes general information such as the manufacturer, weight, or capacity. However, more specific information is also required, such as the CO2 footprint, minimum, nominal, and maximum voltage, or the EU declaration of conformity. All this information is to be included in the labeling planned from August 2028 and from February 2027 by means of a QR code. Even if the type of the first marking is not specified, a QR code is also suitable for this. Depending on the size of the batteries, the labeling requirement may present manufacturers with a further challenge. This is because QR codes have a minimum size of 1 cm by 1 cm according to ISO standard 18004.
The exact requirements can be found here.
Ecodesign for Sustainable Products Regulation (ESPR)
The Ecodesign for Sustainable Products Regulation (ESPR) is the proposal for a regulation that aims to make the EU market more sustainable. It will replace the current Ecodesign Directive (2009/125/EC) and introduce stricter ecodesign criteria for a wider range of products. There is no specific introduction date. The regulation is only aimed at products that have no, or only inadequate, legal provisions. However, there is still no specific information on individual products.
Additionally, it will also introduce a new Digital Product Passport (DPP) requirement for certain product groups. The DPP is a digital document that contains information about a product’s environmental sustainability, such as its durability, repairability, recycled content, and availability of replacement parts. In that, it is very similar to the existing battery passport and intends to:
- help consumers and businesses make purchasing decisions,
- facilitate repairs and recycling,
- improve transparency on the life cycle impacts of products on the environment,
- assist authorities in carrying out inspections.
The ESPR is still under development, and the specific product groups for which a DPP will be required have not yet been determined. However, the regulation is expected to go into effect in 2024. Looking at the objectives and the planned requirements, there is already a similarity to EU Regulation 2023/1542.
Transparency With Track-and-Trace
The new battery law and Digital Product Passport serve as a track-and-trace system and are designed to point out information about a product’s origin, composition, repair, and recycling options. This transparency makes it easier for consumers to opt for more sustainable versions of items. A more mindful buying public achieves added value for responsibly manufactured products and the work of waste management companies is also facilitated by concrete instructions on how to disassemble and recycle. This enables all stakeholders to take a more active role in the shift to a more sustainable economy.
With the introduction of a track-and-trace system, each product must be provided with a serial number, usually randomized. Requirements and regulations are constantly adapted in a digitization project of this kind. This makes it an ongoing project that requires continuous attention.
This is where tracekey comes in. We support our customers with a software solution that is constantly adapted to current regulations so that you no longer have to worry about your regulatory compliance.
Advantages of tracekey
tracekey has already experienced the introduction of track-and-trace systems in two industries. Thanks to our experience in pharmaceutical and MedTech fields, we have become experts in digitalization. As a SaaS provider, we aim to make the work and the lives of our customers easier. With state-of-the-art software technology and accomplished experts in our team, we help our customers overcome the hurdles of digitization with ease and achieve regulatory compliance without any problems.