ECOLABELLING of Portable Rechargeable Batteries RECHARGE s APPROACH 1. OBJECTIVE RECHARGE s objective is to contribute to the development of criteria for the Ecolabelling of Portable Rechargeable Batteries based on existing Technical and Safety Standards as well as selected Environmental Performance Criteria which are based on information accepted and recognised on an International basis by the Battery Industry and other stakeholders. 2. INTRODUCTION There are regulatory and legislative requirements for the labelling of portable rechargeable batteries according to technical characteristics of these batteries such as their capacity (Ah) or their energy content (Wh). There are also legislative requirements regarding the labelling of an environmental protection mark (crossed out wheelie bin). More recently, it has been proposed to introduce labels that could be representative of some environmental performances parameters (Carbon Footprint, Primary Energy demand, CO2 eq. per unit weight) or safety criteria (protection and/or resistance against Short Circuit), etc. From the EU rechargeable battery recycling industry, there is also a demand for labelling portable rechargeable batteries according to their chemical content (e.g. colour coding as proposed by the Battery Association of Japan and adopted also in North America) in order to increase the recycling efficiency of secondary raw materials contained in spent batteries. 3. ECOLABELLING AS A COMMUNICATION TOOL RECHARGE understands that an Ecolabel can be used by certain parties who want to deliver information to End Users by using simplified communication tools. In such a case, the comparison of performances between one and another battery system needs to be approached carefully due to the complexity and need for coherence between the parameters taken into consideration for the evaluation criteria. August 2010 1
An Ecolabel should be based on objective criteria that can be applied to a majority of products. It should not be selected when it is discrinimatory and particularly when it favours one producer s technology versus other commercial actors. Another approach to Ecolabelling is also the possibility of supplying End Users with battery performance information. This may be achieved in a more complete way via a simplified (e.g. web based ) communication tool. 4. EVALUATION CRITERIA and THE PRB MARKET The complexity of the evaluation of environmental parameters and criteria needs to be considered in the context of the market structure of portable rechargeable batteries (PRB). 1. Rechargeable batteries are mainly sold incorporated in equipment (more than 90 % by weight). 2. A rechargeable battery is designed for the specific application in which it is incorporated. 3. Only a minor fraction of the single cell market is in competition with primary batteries. 4. In most cases, the end user will only use evaluation criteria of the original battery or battery pack at replacement time. This represent also a minor fraction of the market. 5. The environmental performances of the rechargeable battery is inevitably linked to the overall performance of the equipment (charger and appliance) where it is used. RECHARGE has prepared a list of Technical, Safety and Environmental parameters that could be considered as a basis for preparing an Ecobalel of Portable Rechargeable Batteries. They are presented below in Table 1. 5. A HARMONIZED APPROACH RECHARGE is recommending the use of the REGULATION (EC) No 66/2010 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 November 2009 on the EU Ecolabel as a basis before establishing additional Ecolabels. Indeed in order to secure a harmonized approach to Ecolabelling, any independent initiative should consider the requirements of the EU Ecolabel Regulation. In particular, it should consider the provisions of Article 6 3: «EU Ecolabel criteria shall be determined on a scientific basis considering the whole life cycle of products.». In addition, Article 6 4 of the EU Ecolabel Regulation clearly indicates that «EU Ecolabel criteria shall include requirements intended to ensure that the products bearing the EU Ecolabel function adequately in accordance with their intended use.» August 2010 2
6. SELECTION OF CRITERIA A list of recommended criteria for delivering an Ecolabel is presented in TABLE 1. These criteria are based either on voluntary commitment by Industry or on compliance with existing regulation. The proposed criteria address rechargeable batteries characteristics such as technical performance optimization, the use of substances in portable rechargeable batteries, the management of spent batteries at end of life, etc For some appliances using rechargeable batteries, the existence of a repair or resale centre may represent an environmental advantage (offer for second hand parts vs new purchase). The existence of a life cycle analysis of the use of a given battery in a specific appliance may be considered as a decision tool to evaluate the battery performances in a given application. Its existence could be considered as a basis to establish criteria for ecolabelling as mentioned in the EU Ecolabel Regulation. 7. LIMITATION IN THE SELECTION OF CRITERIA. There are criteria that have been recently proposed for eco labelling without establishing a common across industry methodology for the use of these criteria. To ensure consistency across the Industry and accurately account for variations in batteries technologies and designs, it is important first to understand and define the underlying technical assumptions and design relationships involved in developing the Key Environmental Performance Indicators. Otherwise we run the risk of adopting less than optimal schemes for ranking overall environmental performances. In Table 2, RECHARGE is listing a series of criteria that should not be used in absence of an agreed methodology at International level. 8. CONCLUSIONS RECHARGE recommends that the definition of criteria for the Ecolabelling of Portable Rechargeable Batteries should be based on the following proposals. 1. An EU harmonized approach based on the REGULATION (EC) No 66/2010 of the European Parliament and the Council of 25 November 2009 on the EU Ecolabel. 2. The use of criteria proposed in existing European Regulatory and Legislative acts. August 2010 3
3. The use of technical criteria that have received International acceptance among the Battery Industry and relevant Authorities. 4. The proposal for new eco labelling criteria should only be made after establishing a common industry wide methodology regarding their definition, their selection and their use. RECHARGE aisbl August 2010 For any additional information, please contact Mr. J P Wiaux, Director General, at the following e mail address. jpwiaux@rechargebatteries.org www.rechargebatteries.org TABLE 1. List of Potential Criteria for the Ecolabelling of Portable Rechargeable Batteries. POTENTIAL CRITERIA Legislative or Regulatory Context Respect of the provisions of the EU Ecolabel Regulation REGULATION (EC) No 66/2010 Battery Materials Composition (Information on generic) Use of recycled materials (in batteries or other applications) Increased durability through C/D cycles optimization Improved self Discharge Rate Repair Center / Resale Center / Alternative to buying new Use of Colour Coding for chemical content to assist C&R Use of Web Site for information communication Conformity with IEC Std 61960 Conformity with IEC Std 62133 Chemical Content Technical performances information (Capacity in Ah) Technical performances information (Energy in Wh) Easy dismantling/easy removability Free of Charge Take Back System Participation to Batteries Collection Systems in all MS Participation to WEEE Collection Systems in all MS Respect of disassembly requirement from WEEE Achievement of Collection Rates for Spent batteries Achievement of Recycling Rates for Spent Batteries Technical requirements Safety requirements UN Model regulation WEEE Directive 2002/96/EC August 2010 4
Requirements about labour practises at production sites UN requirement (?) TABLE 2. List of Criteria for the Ecolabelling of Portable Rechargeable Batteries that cannot be used without establishing a common across Industry methodology for the evaluation and application of these criteria. NB These criteria can be used internally by one manufacturer to evaluate the environmental impact of a given type of product from various sources. They are not representatives for a comparison of products between several producers in absence of a common internationally accepted methodology. CRITERIA Applies within one range of product of One manufacturer for one application CO2 emissions Primary Energy Demand Not comparable across the many chemical systems and the application where they are used. Not comparable across the many applications Carbon footprint Metal content Not comparable across the many applications Regulated by the Batteries Directive or other specific legislation on chemicals Use of Nano Tech materials Use of Heavy metals Targeted legislation is in preparartion Most rechargeable batteries technologies uses heavy metals There should not be any general limitation on the use of heavy metals in batteries The term "heavy metal has no defined scientific background. (REFERENCE 1) August 2010 5
REF (1). Heavy metals A meaningless Term? A report from the International Union of Pure and Applied Chemistry. Chemistry and Human Health Division. Clinical Chemistry Section, Commission on Toxicology. Published in Pure and Applied Chemistry, Vol 74, N 5, pp. 793 807, 2002. Author: John H. Duffus. August 2010 6