In response to new green trade barriers, the battery industry urgently needs to improve its carbon footprint management system
At present, the new energy industry has become one of the priorities of various countries to promote green economic development. The scale, technological innovation and competitiveness of my country's new energy industry have grown significantly, but it has also encountered new green trade barriers in Europe and the United States. For example, the European Union's newly launched "Battery and Waste Battery Regulations"(hereinafter referred to as the "New Battery Regulations") intends to build green barriers based on battery carbon footprint standards and then dominate the voice of the global battery management system.
Our government attaches great importance to the construction of a product carbon footprint management system. In June 2024, 15 departments including the Ministry of Ecology and Environment jointly issued the "Implementation Plan on Establishing a Carbon Footprint Management System"(hereinafter referred to as the "Implementation Plan"), which clearly prioritized key products such as lithium batteries and formulated and issued carbon footprint accounting rules and standards., will provide strong policy guarantees for the domestic battery industry to respond to green barriers in Europe and the United States. What is the impact of the EU's "New Battery Regulations" on my country's battery industry? How to strengthen government-enterprise interaction during the implementation of the domestic "Implementation Plan", mobilize the enthusiasm of battery companies to participate in carbon footprint accounting, and at the same time strengthen international links and mutual recognition of carbon footprint rules? The author conducts an analysis through this article.
Main contents of the EU's New Battery Regulation and its potential impact
The EU is the first region to pay attention to the recycling of used batteries and take measures. It has successively adopted the "Directive on Batteries and Accumulators Containing Certain Hazardous Substances","Battery Directive" and "Waste Framework Directive" to restrict the recycling of batteries, basically forming a producer responsibility mechanism for power battery production companies to assume the main responsibility for battery recycling. However, EU directives generally provide policy guidance to EU member states, and member states still need to formulate corresponding laws and relevant standards according to their own national conditions.
From the launch of the legislative proposal in December 2020, it took three years to officially take effect on August 17, 2023. The EU's "New Battery Regulation" upgraded the battery control directive to a regulation for the first time, aiming to ensure that batteries placed on the EU market have the entire life cycle. It is sustainable and safe, providing a stronger legal basis for the EU to comprehensively carry out battery control. The New Battery Regulation applies to the full life cycle management of electric vehicle batteries, vehicle starting lighting and ignition batteries (SLI batteries), light vehicle batteries (LMT batteries), industrial batteries and portable batteries. Compared with the previous Battery Directive, which only covered management at the battery scrapping stage, its content shows four new mandatory characteristics.
The first is to enforce the carbon footprint statement. Unify battery carbon footprint requirements and determine a unified calculation method, accounting system boundaries, performance rating and maximum threshold for battery carbon footprint. By setting a carbon footprint threshold, the EU will be promoted to realize the layout of the entire battery industry chain and value chain.
The second is to deepen the disclosure of battery information. Batteries must be stamped with a CE mark that meets environmental requirements. For the first time, digital battery passports, producers provide battery health and life, chemical symbols for over-limit substances, individual collection symbols, capacity labels, basic information labels and QR codes have been introduced. By 2026, an electronic battery information exchange system will be established, allowing regulators, consumers, distributors and recyclers to obtain access to battery information.
The third is to enforce and improve supply chain due diligence. Enterprises are required to fulfill their supply chain due diligence obligations through internal responsibility allocation and information disclosure to ensure transparency and traceability of the supply chain. Integrate upstream supplier risk control measures and establish appeal mechanisms and response strategies to identify risks. Through verification by third-party agencies, data and evidence are provided to regulators to form a comprehensive supply chain due diligence system.
The fourth is to improve the management requirements of battery companies. Put forward higher waste management requirements for battery manufacturers and recycling companies, including setting up a producer responsibility extension system and setting a target for the collection rate of used portable and light vehicles batteries, requiring the lithium recovery rate to reach 50% in 2027 and 80% in 2031. %, cobalt, copper, lead and nickel recovery rates will reach 90% in 2027 and 95% in 2031; New requirements such as the proportion of recycled materials, removability and substitutability, limits of hazardous substances, electrochemical performance and durability, and safety have been added.
The high threshold set by the EU's New Battery Regulation has increased the compliance burden on battery companies and the difficulty of exporting electric vehicle companies. In the short term, my country's battery companies may have difficulty meeting the minimum threshold of regulations due to insufficient supply of recycled materials, or face compliance risks due to complex information and labeling systems, and may also weaken their competitive advantages due to the relatively high carbon strength of their own batteries. In the long run, this regulation will encourage my country's battery export enterprises to accelerate the zero-carbon transformation, promote the renewal and iteration of production technology, force the improvement of the domestic battery life cycle management system, and accelerate the green transformation and upgrading of the battery industry chain and supply chain.
Improving the domestic carbon footprint management system is a strategic measure to break down green barriers
In order to actively implement the deployment requirements of the Party Central Committee and the State Council, in June this year, the Ministry of Ecology and Environment took the lead in drafting and jointly issued the "Implementation Plan" with 14 departments including the National Development and Reform Commission, which clarified the goals and realization paths for carbon footprint management of my country's products, and proposed the establishment of the overall requirements, main tasks and safeguard measures for a carbon footprint management system. Battery-related products such as lithium batteries, new energy vehicles, photovoltaics and electronic appliances have been included in the key products prioritized in the Implementation Plan. From the aspects of carbon footprint management, work pattern, and international mutual trust, the domestic battery industry responds to the New Battery Regulations."points out the direction.
Compared with the EU's "New Battery Regulations" that enforce the carbon footprint statement, the "Implementation Plan" further clarifies the relevant work content and requirements. Unify the requirements for the preparation of product carbon footprint accounting standards, and clarify general standards such as product carbon footprint accounting boundaries, accounting methods, release forms, data quality requirements and traceability requirements. In accordance with the principle of group standards being tested first and gradually transformed into industry standards or national standards, priority will be given to focusing on and developing carbon footprint accounting rules and standards for key products such as lithium batteries. Relying on the national greenhouse gas emission factor database, we encourage and promote the participation of research institutions, industry associations, enterprises and other parties to establish and improve the national product carbon footprint factor database. Up to now, my country has officially released a lithium battery carbon footprint accounting system, as well as group standards such as "Carbon Footprint Quantification Method for Vehicle Lithium Ion Batteries".
Compared with the carbon labeling requirements such as digital battery passports in the EU's New Battery Regulations, the "Implementation Plan" clearly proposes to establish a product carbon labeling certification system. It is necessary to study and formulate product carbon labeling certification management methods, clarify the scope of application, labeling styles, certification processes, management requirements, etc., and will also study and formulate a product carbon footprint certification catalog and implementation rules.
Compared with the supply chain due diligence requirements of the EU's New Battery Regulations, the "Implementation Plan" clearly proposes to establish a hierarchical management system for product carbon footprint. Government departments carry out product carbon footprint grading assessment and management, encourage enterprises to carry out carbon footprint evaluations related to themselves and supply chains, propose to establish a carbon footprint information disclosure system, and encourage enterprises to gradually carry out environmental and climate information disclosure, sustainable (development) information disclosure or voluntary evaluation certification. Increase financial support and encourage investment institutions and rating agencies to incorporate product carbon footprints into ESG and sustainable development due diligence.
Through comparative analysis of the EU's "New Battery Regulations", the author believes that accelerating the implementation of the "Implementation Plan" and establishing and improving the carbon footprint management system will promote the domestic battery industry to break through new green trade barriers, help the development of new quality productivity and "double carbon" The goal is achieved. However, in the next step of implementation, government authorities still need to strengthen overall coordination and promote multiple forces to actively participate in carbon footprint accounting and management. At the same time, it is also necessary to strengthen international and domestic exchanges and dialogue and strengthen international cooperation on carbon footprint rules.
Suggestions on promoting and improving the domestic battery carbon footprint management system
In order to promote the further improvement of the domestic battery carbon footprint management system, the author puts forward the following suggestions.
First, it is recommended to increase the participation of well-known domestic Internet companies in developing digital product management tools and establishing a basic database of carbon emissions throughout the life cycle. In building a carbon footprint management system center, Internet companies have advantages such as digital transformation, technological innovation, ensuring data security, and public communication. Through the research and development of relevant information systems, they can promote enterprises to efficiently carry out carbon emission accounting and information disclosure, and help promote the battery industry. Carbon footprint accounting standards are tested first.
In addition, most well-known domestic Internet companies have established green funds and related business departments in the ecological and environmental fields, and they are willing to participate in the implementation of pilot demonstrations of major domestic ecological and environmental policies. Relevant government departments can provide appropriate guidance to increase their participation in the carbon footprint management system.
Second, it is recommended to rely on the multilateral and bilateral international cooperation mechanism on ecological environment to promote the establishment of a carbon footprint certification system for battery-related industries and promote multilateral and bilateral rating mutual recognition cooperation. Keep up with the new situation and new rules of international trade, establish a carbon footprint certification system for relevant industries based on international standards and domestic realities, establish evaluation levels and corresponding indicators, and standardize the certification process.
At the same time, relying on the multilateral and bilateral ecological and environmental cooperation mechanism, we will promote the establishment of mutual recognition cooperation between China and the European Union and other regional countries on product carbon footprint methodology and product certification testing in battery and other related industries. Domestic battery companies should also follow the new regulations to further improve the compliance of their own products, strengthen upstream and downstream supply chain compliance management by performing due diligence, strengthen cooperation with local European companies, and maintain international market competitiveness by improving product certification and testing capabilities and transparency.
Third, it is recommended to pay attention to the establishment and improvement of a waste lithium battery recycling system. Building a battery recycling system can promote resource recycling and reduce carbon footprints. It is a basic part of establishing a battery carbon footprint management system and breaking green barriers. It is recommended that leading domestic battery companies strengthen cooperation with scientific research institutions, give priority to investigation and research on waste lithium-ion battery pollution, understand the characteristics of process pollution, and provide a basis for scientific policy implementation. At the same time, we will study and formulate technical specifications and standards for the recycling, disposal, and comprehensive utilization of used lithium-ion batteries, standardize the recycling, disposal and comprehensive utilization of industry enterprises, and actively guide enterprises to participate in the construction of social recycling systems.
Encourage the establishment of battery joint recycling and industrial chain complementary recycling models led by industry associations and participated by key enterprises, and establish a paid collection system for small waste batteries in communities, supermarkets and other ecosystems. Combined with battery fire safety precautions, we will increase publicity and popularization efforts, encourage the public to consciously participate in recycling activities, and build a sound and effective social waste battery recycling network system.
Author's unit: Foreign Cooperation and Exchange Center of the Ministry of Ecology and Environment
