EU Battery Passport: The Digital Battery Passport in the New EU Draft Battery Regulation
In October 2017, the European Commission launched the European Battery Alliance (EBA) cooperation platform in order to develop an innovative, competitive and sustainable battery value chain in Europe.
In May 2018, the Commission also adopted the Strategic Action Plan for Batteries as part of the Clean Mobility Package.
Following this, on 10 December 2020, the European Commission published a draft regulation on batteries and waste batteries as an integral part of the Strategic Action Plan for Batteries and the EU Green Deal.
A revised draft of that regulation was published on 10 March 2022.
This update will focus on the provisions of the current draft in relation to the Digital Battery Passport for industrial and vehicle batteries.
The Digital Battery Passport (DBP) is a digital record system that enables the transfer of information between parties.
The DBP, which only applies to industrial batteries, will ensure that recovery organizations can determine the best course of action for waste batteries based on their chemistry and use history.
According to Article 65 of the Draft Regulation:
“1. From 42 months after entry into force of the Regulation each LMT battery, each industrial battery with a capacity above 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (“battery passport”).
2. The battery passport shall contain information relating to the battery model and information specific to the individual battery including as a result of the use of that battery, as set out in Annex XIII.”
To be able to achieve a sustainable battery lifecycle, electronic battery passports and QR codes will provide us with clearer labeling and information.
To be listed in the European market, each battery must have a unique battery passport and responsibility will be on the economic operator placing the battery on the market to ensure that the data included in the battery passport is accurate, complete, and up-to-date.
According to Article 65(6a), if a battery has been subject to preparation for re-use, repurposing, or remanufacturing, the responsibility to ensure that the information in the battery passport is accurate, complete, and up to date shall be transferred to the economic operator that has placed that battery on the market or has put it into service.
In this case, the battery will have a new battery passport but this one will be linked to the original battery.
In the event that there is a change in status from battery to a waste battery, the responsibility to ensure that the information in the battery passport is accurate, complete, and up to date shall be transferred to either the producer, the producer responsibility organization acting on their behalf as per Article 47a(2), or the waste management operator referred to in Article 54a.
A battery passport shall cease to exist after the battery has been recycled according to Article 65(6b).
The previous version of the Draft Regulation, which was published on 27 October 2021, simply required a battery passport to contain information on:
- Basic characteristics of the battery such as its type and model
- Identification in the form of a unique identifier
- Performance and durability characteristics
This was criticized by industry because this information is commercially sensitive.
Therefore, it was suggested that not all information should be made available to consumers.
The battery passport envisaged by the revised draft regulation must contain the following three types of information, depending on the party who is accessing the information:
- Information accessible to the general public,
- Information accessible only to notified bodies, market surveillance authorities and the EU Commission
- Information accessible only to any natural or legal person with a legitimate interest in accessing and processing that information
This information will be accessible through a QR code. Both the QR code and the unique identifier need to comply with the standard ISO/IEC 15459:2015 or equivalent.
According to the latest draft regulation, “unique identifier” means “a unique string of characters for the identification of batteries that also enables a web link to the battery passport”.
According to Article 65(5):
“All information included in the product passport shall be;
- Based on open standards,
- Developed with an inter-operable format and,
- Shall be transferable through an open interoperable data exchange network without vender lock-in and,
- Shall be machine readable, structured, and searchable, in accordance with the essential requirements set out in Article 65a.”
This update focused on the provisions of the current draft regulation in relation to the Digital Battery Passport only.
Further details regarding other provisions of the revised draft can be found in the Expert Commentary from Cooley LLP dated 24 January 2023 and the Regulatory Update Comment dated 9 February 2023.
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