Is a restriction of primary batteries the most sustainable option to support the Green Deal and Circular Economy Action Plan?

Primary Batteries are an indispensable part our daily lives and can last years especially in devices with a low energy demand. That’s why they should not be considered as single-use products. In addition, primary batteries have a better eco-balance versus rechargeables in low drain devices. The European Commission is currently reviewing the Batteries Directive 2006/66/EC with a main focus on environmental sustainability. The proposed measures under discussion include a restriction or even a total ban of primary batteries. To further drive eco-efficiency, promote safety and avoid unnecessary waste, EPBA proposes a minimum Battery Quality Standard.

EPBA sees merit in setting minimum quality standards which will ensure European consumers have the safest and highest-quality choices available to power their appliances. The IEC standard 60068-2 (Physical and electrical specifications of primary batteries) can be a good starting point for these discussions. This could also be used to look into stricter health and safety aspects such as requirements for leakage prevention.


Primary batteries are the most environmentally sustainable solution for low drain applications

Different LCAs confirm that primary batteries are more environmentally sustainable for low drain applications (i.e. applications requiring lower power levels) than rechargeable batteries. The lower and more efficient discharge level of primary batteries combined with the need for repeated recharging of rechargeables makes primary batteries the best choice for low drain devices since these require lower power levels. Half of today’s market for appliances is focused on miniature, portable, lightweight, low drain applications and the prospects point to continued growth on this segment. On average a household (195 million in EU) has 23,9 battery-powered devices. Furthermore, many applications exist, which are not suitable for recharging due to technical constraints like accessibility, as well as physical constraints like high temperature (e.g. smart agriculture) and explosive atmosphere (oil and gas industry). Additionally, there are a lot of military applications mandatorily using primary cells like ASW-sonar buoys.


A phase out would not benefit the environment

The European Commission is reviewing the Batteries Directive and commissioned the Öko Institute an independent assessment about different measures including a restriction or full prohibition of primary batteries. The assessment of the Öko Institute highlighted that banning primary batteries would not bring any environmental benefit. A prohibition of primary batteries would only have a moderate effect on the amount of waste batteries (-25 % by weight), while there would be a huge negative impact on the environment, in particular, global warming, human toxicity, aqua toxicity and environmental acidification.Various key sectors using primary batteries and would be severely impacted by a ban: medical, ICT, electronics, just to name some. Such a measure will worsen the greenhouse gas emission, increase waste and affect negatively different industries.

Primary Batteries are not single use products

Comparing primary batteries with everyday single use product like certain plastics where no organised collection and recycling infrastructure exists underestimates the complexity and technology behind the product as well as its importance to a number of essential applications and sectors. Primary batteries are energy sources and they can be used many times in one or even in multiple devices until their end of life. Using the term “single use batteries” is highly misleading because in numerous applications they provide power for up to two decades without being replaced or recharged.

EPBA response to the Inception Impact Assessment


EPBA Statement on the proposal to restrict primary batteries


EPBA Infographic Primary Batteries