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Environmental Regulations for Secondary Batteries and the Rise of Digital Product Passports in the EU

General Report April 27, 2025
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TABLE OF CONTENTS

  1. Summary
  2. Current and Emerging Environmental Regulations for Secondary Batteries
  3. Understanding the Digital Product Passport Framework
  4. Integrating DPPs into Secondary Battery Regulation
  5. Case Study: Smartphone Battery Labels and Repairability Mandates
  6. Remanufacturing and Circular-Economy Synergies
  7. Implications and Strategic Considerations for Industry
  8. Conclusion

1. Summary

  • The evolving regulatory landscape concerning secondary (rechargeable) batteries within the European Union is characterized by increasing emphasis on sustainability, traceability, and harmony with circular economy principles. By April 27, 2025, a significant framework has been established through updated environmental regulations aimed at transforming the battery production and end-of-life treatment processes. Notable measures include stricter mandates on eco-design, emphasizing durability and repairability while aligning production with broader sustainability goals. The recent amendments to the EU Battery Directive, in response to the Ecodesign for Sustainable Products Regulation (ESPR), reflect a progressive commitment to enhance the recyclable and reusable nature of batteries, thereby mitigating ecological impacts and addressing resource depletion issues.

  • In parallel to these regulatory shifts, the introduction of Digital Product Passports (DPPs) represents a substantial innovation in how product information is documented and shared. Set to become mandatory by 2026, the DPP framework is designed to provide comprehensive data on the entirety of a product's lifecycle—from material sourcing and manufacturing processes to end-of-life treatment. This initiative fosters enhanced transparency among stakeholders, thereby empowering consumers to make informed choices and facilitating the integration of sustainable practices across the supply chain. A case study focusing on new smartphone battery labels illustrates the early steps towards implementing standardized information that supports repairability and environmental awareness. As stakeholders prepare for the transition, the implications for manufacturers, recyclers, and consumers become ever more pronounced, necessitating adaptive strategies to leverage the benefits introduced by DPPs.

  • The convergence of these regulatory frameworks sets a course towards more sustainable practices in industries reliant on batteries, with the expected outcome of streamlined recycling processes and enhanced accountability. As compliance deadlines approach, the focus on integrating DPPs with existing operations becomes critical for stakeholders aiming to maintain competitive advantages within the market while contributing to the EU’s ambitious circular-economy goals.

2. Current and Emerging Environmental Regulations for Secondary Batteries

  • 2-1. Overview of EU Battery Directive and recent amendments

  • The EU Battery Directive, which has undergone several amendments, represents a critical regulatory framework governing the lifecycle management of batteries within the European Union. The Directive aims to ensure that batteries are produced and disposed of in environmentally sustainable ways, addressing the growing environmental concerns related to battery waste and resource depletion. Recent amendments, particularly those proposed within the context of the Ecodesign for Sustainable Products Regulation (ESPR), emphasize enhanced durability, repairability, and recyclability of batteries, aligning with the broader EU objectives of circular economy integration and sustainability. Notably, the Directives establish essential requirements for battery manufacturers concerning safety standards, material sourcing, and the end-of-life treatment of batteries.

  • 2-2. Design-for-environment criteria: materials, performance, safety

  • The design-for-environment criteria outlined in the current regulatory landscape focus on several key aspects: the sustainability of materials used in battery production, the performance standards required of the batteries, and stringent safety measures. Under the recently adopted amendments, manufacturers are encouraged to utilize sustainable raw materials, promote the use of recycled content, and minimize the environmental impact throughout the product's lifecycle. Enhanced performance standards are aimed at increasing the longevity and efficiency of batteries, thus contributing to a reduction in waste and resource consumption. Safety regulations are critical to prevent hazards associated with battery use, ensuring that products are safe for consumers and pose minimal risk to the environment during their entire lifecycle.

  • 2-3. End-of-life obligations: collection, recycling, recovery targets

  • The end-of-life obligations set forth in the EU's regulatory framework highlight the requirements for battery collection, recycling, and recovery targets. As of April 2025, EU regulations mandate that all batteries placed on the market must be collected and recycled to prevent environmental contamination. The collection target aims for a minimum percentage of batteries to be returned for recycling, thereby reducing landfill use and promoting the reuse of materials. Recycling processes are also regulated to ensure that hazardous substances are handled appropriately, and valuable materials are recovered. The 2026 timelines established under the aforementioned amendments further solidify these obligations, pushing manufacturers to align their practices with the EU's sustainability goals.

  • 2-4. Planned updates under the EU’s Sustainable Products Initiative

  • The Sustainable Products Initiative (SPI), adopted in 2024 and forming part of the EU’s broader strategy for promoting circular economy practices, is poised to introduce significant updates to existing battery regulations. This initiative outlines ambitious targets aimed at guiding product design and manufacturing toward greater environmental sustainability while supporting economic resilience. The SPI emphasizes the importance of harmonized sustainability standards across member states, thus facilitating market access for eco-friendly products. Under this initiative, an expanded scope of environmentally friendly practices, including stricter guidelines on resource efficiency, recyclability, and repairability, is planned to be rolled out progressively in the coming years. Stakeholders are encouraged to participate in consultations as the EU establishes detailed technical guidelines.

3. Understanding the Digital Product Passport Framework

  • 3-1. Definition, objectives, and key features of DPPs

  • The Digital Product Passport (DPP) represents a significant shift in how product information is tracked and shared throughout a product's lifecycle. Essentially functioning as a digital record, the DPP encapsulates vital details about a product—from raw material sourcing to manufacturing processes and ultimate disposal. It is intended to serve as a product's 'ID card, ' accessible through various methods including QR codes and RFID tags. Central to its design is the aim to enhance transparency among stakeholders, empowering consumers to make informed decisions while also facilitating the transition to a circular economy by ensuring products are more sustainable, repairable, and recyclable.

  • The DPP stems from the European Union’s Ecodesign for Sustainable Products Regulation (ESPR), enacted within the framework of the European Green Deal. This regulatory initiative aims to bolster sustainability, reduce waste, and promote a circular economy by mandating that products sold within the EU feature accessible, detailed information about their lifecycle.

  • Key features of the DPP include comprehensive data points covering the product's composition, material origin, environmental impact, production methods, repair instructions, and recycling guidelines. This wealth of information ensures that consumers, businesses, and regulatory authorities can access an accurate, up-to-date overview of each product, thereby reinforcing accountability and supporting sustainability efforts.

  • 3-2. EU legislative timeline leading to 2026 mandatory use

  • The legislative framework surrounding Digital Product Passports is moving toward a critical implementation phase, with full compliance expected by 2026. This timeline signifies a pivotal moment for manufacturers, importers, and sellers in the EU market, as they will be required to provide specific digital information regarding their products. The urgency of the timeline has intensified, compelling businesses to prepare for the impending regulations and adapt their operations accordingly.

  • As part of the regulatory process, the European Commission has outlined the steps necessary for DPP implementation, which includes stakeholder consultations, technical standard developments, and pilot programs to facilitate practical testing of the DPP system across various industries. The expectation is that by 2026, adherence to the DPP regulations will be compulsory for many products across critical sectors such as electronics, textiles, and automotive, necessitating that businesses establish robust data collection and management systems well in advance.

  • 3-3. Technical components: RFID, blockchain, data standards

  • The technical architecture of the DPP leverages advanced technologies such as RFID (Radio Frequency Identification) and blockchain to ensure accurate tracking and management of product data. RFID technology plays a crucial role in enhancing traceability, enabling automated reading of product identifiers without requiring a line of sight, which streamlines the process of data collection.

  • Furthermore, blockchain technology underpins the DPP by providing a secure and tamper-proof method for storing product data. This enables stakeholders to verify information efficiently and promotes transparency. The ongoing development of data standards is also a critical aspect of this initiative, ensuring that all participants within the supply chain share a common framework for product information, which improves interoperability and compliance with regulatory demands.

  • 3-4. Sectoral scope: from electronics to cosmetics

  • The implementation of Digital Product Passports spans a wide array of sectors, reflecting the EU's intent to foster sustainability across multiple industries. Initial focus will include high-impact sectors such as electronics, where DPPs will track components like batteries and hazardous materials, alongside providing information on recycling pathways.

  • Additionally, the cosmetics industry is also poised to adopt DPPs, with brands preparing to offer transparency regarding ingredients, sourcing practices, and environmental impact through accessible digital records. This broad sectoral scope not only highlights the EU's ambition for comprehensive sustainability but also aims to meet growing consumer demands for accountability and ethical practices.

  • As the requirements for DPPs proliferate, industries like furniture, textiles, and automotive are gearing up to align with the regulatory framework, which promises to redefine product transparency and sustainability standards across the market.

4. Integrating DPPs into Secondary Battery Regulation

  • 4-1. Mapping battery-specific data fields: materials, performance, safety

  • The integration of Digital Product Passports (DPPs) into secondary battery regulation entails the systematic mapping of battery-specific data fields, which include critical information on materials, performance metrics, and safety certificates. Under the forthcoming Ecodesign for Sustainable Products Regulation (ESPR), set to become mandatory by 2026, manufacturers will be required to include comprehensive data about the battery’s lifecycle. This includes the sourcing of raw materials, their subsequent processing, and final usage stages. By establishing these data fields, stakeholders can ensure that all aspects impacting the environment and user safety are documented and monitored, thereby increasing accountability across the supply chain.

  • 4-2. Traceability of critical minerals and provenance requirements

  • One of the foremost challenges in integrating DPPs within battery regulation is ensuring the traceability of critical minerals. As demand for sustainable lithium-ion batteries grows, the need for transparency regarding the origin of materials becomes increasingly urgent. DPPs will facilitate the tracking of minerals back to their source, thus adhering to provenance requirements mandated under EU law. This approach seeks to mitigate issues related to unethical mining practices and environmental degradation. By incorporating precise data on the birthplace of minerals, the battery industry can foster trust among consumers and regulatory bodies, ultimately aligning with the EU’s broader sustainability goals.

  • 4-3. Linking DPP records to end-of-life treatment and recyclers

  • Within the framework of upcoming regulatory changes, another critical aspect of integrating DPPs will be linking DPP records directly to end-of-life treatment protocols and recyclers. The DPP will provide essential data that informs recyclers about the specific composition of batteries, allowing them to implement effective recycling processes tailored to these materials. By ensuring that DPPs contain information such as the types of materials used and their recyclability, regulations can enhance recovery rates and reduce waste. This streamlined data flow is vital not only for regulatory compliance but also for advancing circular economy initiatives in the battery sector.

  • 4-4. Regulatory enforcement and penalties for non-compliance

  • As the EU gears up for the mandatory adoption of DPPs, regulatory enforcement mechanisms are becoming paramount. Non-compliance with DPP requirements can lead to significant repercussions for manufacturers, including financial penalties and restrictions on product sales within the EU market. Correspondingly, the regulatory framework will likely incorporate robust verification systems to ensure compliance, thereby incentivizing companies to adhere to the new data-sharing protocols. This impending enforcement landscape emphasizes the need for early adoption and adaptation to the DPP framework to avoid disruptions in market access and bolster environmental standards.

5. Case Study: Smartphone Battery Labels and Repairability Mandates

  • 5-1. EU’s new energy-efficiency, durability, and repairability labels

  • On April 24, 2025, the European Union (EU) officially announced the implementation of new mandatory labels for smartphones and tablets sold within the bloc. These labels, which will be in effect for devices sold from June 20, 2025, aim to provide consumers with clear and standardized information regarding energy efficiency, durability, and repairability. This initiative is part of a broader push towards sustainability in product design, aligned with the EU's ecological goals.

  • The labels will feature an energy efficiency rating graded on a scale from A to G, similar to existing labels found on household appliances. They will also provide essential details such as the device’s battery life, the number of charge cycles that the battery can withstand, and specific ratings for durability and repairability. In addition to these metrics, the labels will reflect the device's ingress protection (IP) rating, which indicates its resistance to dust and water. This comprehensive labeling effort is geared towards enhancing consumer awareness and aiding decision-making in purchasing more sustainable products.

  • 5-2. Implementation timeline: June 2025 rollout

  • The deadline for compliance with the new labeling requirements is set for June 20, 2025. Devices released on or after this date will need to display these new labels, ensuring that consumers can easily access critical information about their potential purchases. This timeline emphasizes the EU's strategic approach to fostering an informed consumer base that prioritizes sustainability in their purchasing decisions.

  • With this rollout, manufacturers are under pressure to not only design their products to meet these new labeling standards but also comply with accompanying 'ecodesign requirements.' These requirements include the need to provide readily available spare parts for repairs, thus enhancing the repairability of devices sold in the EU market.

  • 5-3. Information requirements versus DPP data overlap

  • The information included in the new battery and repairability labels intersects significantly with the data expected to be included in the upcoming Digital Product Passports (DPPs). Both initiatives strive to enhance transparency regarding product performance and sustainability. The labels will provide immediate consumer-facing information, while DPPs are designed to give a more detailed account throughout the product's lifecycle, which includes data on materials used, safety testing, and recycling pathways.

  • This overlap raises important questions regarding data management and storage. As manufacturers gear up for these requirements, there is a push to ensure that the data they gather for the labels can be effectively integrated into their long-term DPP strategies. By harmonizing both data sets, companies can streamline compliance and offer consumers a comprehensive view of their product’s environmental impact.

  • 5-4. Lessons for broader battery-sector transparency

  • The introduction of mandatory battery life and repairability labels marks a critical step towards greater transparency within the battery sector. As consumers become more eco-conscious, the demand for detailed information on product sustainability is growing. This initiative not only informs consumers but also pressurizes manufacturers to enhance the sustainability of their products throughout the supply chain.

  • By implementing such labeling, the EU sets a precedent that could influence global standards, promoting a shift towards a more sustainable circular economy. Lessons learned from this initiative could inform future regulations across various sectors, emphasizing the importance of accessibility to environmental data for consumers, ultimately paving the way for enhanced industry accountability and innovation.

6. Remanufacturing and Circular-Economy Synergies

  • 6-1. Role of remanufacturing in achieving net-zero targets

  • Remanufacturing plays a critical role in the global transition to net-zero emissions. By reprocessing used products to bring them back to a 'like-new' condition, remanufacturing significantly extends the lifecycle of materials and components. This practice not only reduces the demand for virgin resources but also cuts down on the carbon emissions associated with manufacturing new products. Estimates indicate that remanufacturing can lead to emission reductions of up to 80% when compared to the production of new items, illustrating its potential as a vital strategy in inventory and resource management as industries strive for net-zero goals.

  • 6-2. How DPP data supports reverse logistics and quality control

  • Digital Product Passports (DPPs) serve as a crucial enabler of effective reverse logistics, facilitating the efficient return and remanufacturing of products. By embedding key data within DPPs, businesses can trace products' materials and components throughout their lifecycle. This traceability enhances quality control processes, ensuring that returned items meet stringent safety and performance standards before being remanufactured. Moreover, DPPs provide valuable insights that help companies optimize inventory management, reduce waste, and align with circular-economy principles.

  • 6-3. Economic and resilience benefits of second-life batteries

  • Second-life batteries, which refer to batteries that have completed their primary use but still retain significant capacity for further applications, present both economic and resilience advantages. By remanufacturing and repurposing these batteries—often pulled from electric vehicles—businesses can tap into a cost-effective source of energy storage systems. This not only reduces the dependency on newly mined materials but also creates opportunities for innovation in energy management solutions. Additionally, the growing second-life battery market enhances supply chain resilience by providing alternatives to critical materials that are subject to market volatility.

  • 6-4. Barriers and enablers for uptake

  • Despite the numerous benefits, several barriers hinder the widespread uptake of remanufacturing practices. One major challenge is the lack of regulatory support and uniform standards governing remanufactured products, which often leads to uncertainties around quality and reliability. Additionally, there are technological barriers such as the need for advanced processing methods to restore products to their original standards. On the other hand, enablers like increasing public awareness of sustainability, the emergence of supporting regulations like the EU Ecodesign for Sustainable Products, and collaborative frameworks among stakeholders are vital in driving the adoption of remanufacturing in the circular economy.

7. Implications and Strategic Considerations for Industry

  • 7-1. Supply-chain coordination and digital infrastructure needs

  • As the Digital Product Passport (DPP) framework is set to become mandatory in 2026, industry stakeholders must focus on enhancing supply-chain coordination. This involves integrating advanced digital infrastructures to facilitate seamless data sharing among various stakeholders, including manufacturers, suppliers, and recyclers. The interconnected nature of the DPP necessitates that all participants in the supply chain, from raw material sourcing to end-of-life treatment, overhaul their data management practices to ensure consistency and accuracy. Companies that proactively invest in robust digital solutions will not only meet compliance requirements but will also enhance operational efficiencies and responsiveness to market demands.

  • 7-2. Data governance, interoperability, and cybersecurity

  • The DPP's success hinges on effective data governance and interoperability across different platforms and sectors. Businesses need to establish comprehensive policies to secure sensitive information, ensure data accuracy, and facilitate the smooth exchange of information. Cybersecurity will be paramount, as breaches could jeopardize compliance and trust in the DPP system. Adopting standardized formats and protocols will be essential for diverse industries to communicate effectively while maintaining the integrity of product data. Companies that prioritize these elements will be well positioned to leverage the DPP as a competitive advantage.

  • 7-3. Cost-benefit analysis of early DPP adoption

  • Conducting a cost-benefit analysis of early DPP adoption is crucial for companies contemplating their compliance strategies. Benefits may include improved customer trust, enhanced brand reputation, and access to markets that prioritize sustainability, outweighing the initial investment and operational changes required. Early adopters stand to gain significant market advantage as they pioneer sustainable practices and product transparency. As competitors scramble to comply closer to the deadline, businesses that have integrated the DPP into their operations from the outset will not only meet regulatory expectations but also position themselves as leaders in the shift toward sustainability.

  • 7-4. Positioning for competitive advantage and sustainability leadership

  • The introduction of the DPP presents a unique opportunity for businesses to position themselves as sustainability leaders. By transparently providing detailed product information and engaging in circular economy practices, companies can foster consumer trust and loyalty. Businesses should develop strategies that not only comply with the DPP but also highlight their commitment to environmental stewardship. This could involve leveraging the data insights from the DPP to improve product design, reduce waste, and innovate in recycling efforts. Firms that integrate sustainability into their core business strategies will likely enjoy enhanced competitiveness, improved market share, and increased stakeholder engagement.

Conclusion

  • As of April 2025, the confluence of stringent environmental regulations for secondary batteries and the imminent rollout of Digital Product Passports signals a pivotal transformation for the EU’s aspirations toward a circular economy. This regulatory landscape aims to embed rich and standardized data across the entire lifecycle of products, thereby enhancing material transparency, optimizing recycling protocols, and promoting remanufacturing practices. It is incumbent upon manufacturers to proactively invest in developing the digital and organizational capabilities required for effective management and sharing of DPP information. Such investments are not merely compliance measures; they represent vital steps toward leadership in sustainability and operational excellence.

  • Looking forward, a collaborative approach involving policymakers, technology providers, recyclers, and end users will be instrumental in unlocking cost efficiencies and achieving robust sustainability gains. The harmonization of DPP data formats beyond the EU, coupled with the utilization of emerging digital-ledger technologies, has the potential to accelerate global adoption of these practices. This strategic alignment can ultimately foster a truly circular battery economy, enhancing resilience while addressing mounting environmental challenges. Companies that embrace and integrate these new standards will not only fulfill regulatory obligations but also position themselves as innovators in the shift toward sustainable practices, thereby setting the foundation for a more resilient and accountable industry.

Glossary

  • Secondary Batteries: Secondary batteries are rechargeable energy storage devices used in various applications, from consumer electronics to electric vehicles. These batteries can be cycled multiple times, offering significant advantages over primary batteries, which are single-use. The European Union has established regulations aimed at enhancing the sustainability and recyclability of these batteries in alignment with its environmental objectives.
  • Digital Product Passport (DPP): The Digital Product Passport is a regulatory framework being implemented by the European Union to improve transparency and information sharing about products throughout their lifecycle. By 2026, all products sold in the EU will be required to include detailed data on materials, production, and disposal to support sustainability efforts and facilitate a circular economy.
  • Ecodesign for Sustainable Products Regulation (ESPR): The ESPR is a key aspect of the European Green Deal that mandates environmentally friendly design practices for products sold in the EU. It aims to enhance product sustainability, requiring manufacturers to consider the entire lifecycle of a product, from production through to disposal, thereby promoting circular economy principles.
  • Circular Economy: The circular economy is an economic model aimed at eliminating waste and promoting the continual use of resources. Unlike the traditional linear economy, which follows a 'take-make-dispose' pattern, the circular model focuses on reusing, recycling, and remanufacturing to create a more sustainable approach to consumption and production.
  • Repairability: Repairability refers to the ease with which a product can be repaired, typically influenced by design choices that affect accessibility to components and the availability of spare parts. Increasing repairability is a central goal within the EU's sustainability regulations, supporting longer product lifespans and reducing waste.
  • Lifecycle Tracking: Lifecycle tracking involves documenting and monitoring a product's journey from raw material extraction through to production, use, and ultimate disposal. This practice is central to initiatives like the Digital Product Passport, enabling improved transparency and accountability in sustainability efforts.
  • Compliance Deadline: The compliance deadline is a set date by which businesses must meet specific regulatory requirements. For instance, the EU mandates that by 2026, all products must incorporate Digital Product Passports, necessitating that manufacturers prepare their data management systems ahead of this deadline to ensure compliance.
  • Remanufacturing: Remanufacturing is the process of restoring used products to a 'like-new' condition, enabling them to be reused rather than discarded. This practice not only conserves resources but also aligns with the goals of a circular economy by dramatically reducing waste and emissions associated with new product manufacturing.
  • RFID (Radio Frequency Identification): RFID is a technology that utilizes radio waves to identify and track objects automatically. In the context of Digital Product Passports, RFID enables efficient data collection regarding the lifecycle of products, enhancing traceability and inventory management across supply chains.
  • Blockchain: Blockchain is a decentralized digital ledger technology that securely records transactions across multiple computers, ensuring data integrity and transparency. Its application in Digital Product Passports conditions the traceability of product data, supporting compliance and consumer trust.
  • EU Battery Directive: The EU Battery Directive is a regulatory framework governing the production and management of batteries within the European Union. It aims to ensure that batteries are designed for sustainability, emphasizing issues like safety, resource efficiency, and environmental impact. Recent amendments have introduced stricter requirements regarding recyclability and repairability.
  • Provenance Requirements: Provenance requirements refer to regulations that mandate the tracing of materials back to their source to ensure ethical and sustainable procurement. In the context of the battery industry, these requirements seek to prevent unethical mining practices and promote environmental responsibility.
  • End-of-Life Treatment: End-of-life treatment encompasses the processes involved when a product is no longer usable, including collection, recycling, and disposal methods. Effective end-of-life strategies are crucial for minimizing environmental impact and ensuring compliance with EU regulations surrounding waste management.

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