1. Nordic Swan Ecolabelling
Presentation of proposed draft criteria, gen. 5, Primary batteries

2. Agenda Nordic Ecolabel criteria for primary batteries
Goals of the criteria revision
Criteria development process
Draft criteria – proposed changes
Questions
Closing Remarks
My name is Thomas Christensen, project manager, Nordic project group
Your comments/feedback today are not considered as official consultation comments. You have to comment the final draft proposal – submit comments to
The final draft proposal i located on the Nordic webside:

3. Nordic Ecolabel criteria for primary batteries
Criteria generation 1
Approved 1996
Criteria generation 2
Criteria generation 3
Criteria generation 4
Valid until 31 October 2019
Criteria generation 5
Approved November 2018
An overlap of minimum 1 year between generation 4 and 5 in order to comply with the new requirements.

4. Goals of the criteria revision
To consider new or stringent requirements within the following areas of the criteria:
Use of resources in batteries and packaging
Corporate Social Responsibility regarding for sourcing of “conflict- free” mineral, critical raw materials and working conditions
Battery Minimum Average Duration (MAD), battery shelf life, test methods, safety and quality
New public consultation process
Evaluation in – approved by Nordic Ecolabelling Board: Clear recommendations for the goals of the criteria revision

5. Criteria development for Nordic Swan Ecolabel
The criteria for granting a licence for an ecolabel are revised at regular intervals – usually every 4-5 years – to ensure that ecolabelled products continue to be some of the most environmentally-sound products on the market.
The development of new criteria starts with a preliminary study to analyse the potential for ecolabelling a new product group. If there is a basis for developing a set of criteria, a 9-12-month development process is initiated.
When the criteria are developed within a certain product group and when they are later revised, Nordic Ecolabelling host a public hearing. You have the possibility to influence the process through comments and proposals during this hearing. After the hearing final adjustments are made, before the new criteria document is adopted and the products or services of the companies can be certified.
About halfway during the criteria cycle the criteria are evaluated in a preliminary study with a view to possible revision. This process runs in parallel with the existing criteria document, so a revised criteria document can be ready 1 year before the valid criteria document expires. This allows licence holders to make the necessary adjustments to fulfil the new criteria.

6. Overall project plan
Overall project plan for revision of Nordic Swan Ecolabelling criteria for primary batteries, generation 5.
The consultation is divided into the 3 preliminary steps, each step focusing on a relevant area in the products life cycle.
Consultation on draft new criteria for primary batteries, generation 5.
Published: 23/3
Deadline for comments: 15/4
Published: 16/4
Deadline for comments: 29/4
Published: 30/4
Deadline for comments: 25/5
Date: 29. June 2018
Published: 25/6
Deadline for comments: 12/8
Published: New criteria for primary batteries, generation 5.
November 2018
Step 1 -
Use of resources in batteries and packaging.
Step 2 -
CSR regarding for sourcing of “conflict-free” mineral, critical raw materials and working conditions.
Step 3 - Battery Minimum average duration (MAD), shelf life, test methods, safety and quality.
Webinar – presentation of draft New criteria for primary batteries, generation 5.
Step 4 -
Draft New criteria for primary batteries, generation 5.
Step 5 -Published New criteria for primary batteries, generation 5.
We need all your comments – Please submit any comments to by August 12, 2018 at the latest.

7. Draft criteria – proposed changes

8. Draft criteria – proposed changes
O1 Description of the product
The applicant must submit the following information about the product(s):
Brand and trading name(s).
Name and contact details of production location(s) for the manufacture and brand owner(s) of batteries.
Description of the product(s), detailing all constituent substances present in the battery metals, other solid substances and liquid chemical substances) in the application (weight %) and materials used in the outer container.; cathode-and anode ingredients, electrolyte solutions, conductor-, separator- and container ingredients and other materials.
Description of materials used in the primary packaging. Primary packaging: refers to the purchase packaging for the consumer, e.g. the packaging that holds 4 batteries, and which the consumer encounters in sales.
Description of the manufacturing process for the product. Nordic Ecolabelling wants a general description of the batteries manufacturing process and which technology that is being used to produce the batteries. A flow chart is recommended to explain the production process.
It is important that Nordic Ecolabelling gets information on all production sites producing Nordic Swan ecolabelled primary batteries as several requirements involves the individual production site, e.g. waste-handling and quality requirements. In connection with handling of the application, Nordic Ecolabelling normally performs an on-site inspection on all production sites to ensure adherence to the requirements.
Nordic Ecolabelling wants a description of the batteries (detailing all constituent substances, metals, other solid and liquid substances present in the batteries). This information is relevant in order to get detailed information on the material composition in order to fully understand the products and future requirements for the use of resources.

9. Draft criteria – proposed changes
O2 Metal content of batteries
The metal content of the battery may not exceed the following limits:
It should be noted that the EU’s Battery Directive 2006/66/EC permits a maximum cadmium content of 20 ppm and a maximum mercury content of 5 ppm. The test laboratory may need special equipment in order to test batteries for a mercury content of < 0.1 ppm and lead content of <10 ppm.
At least four examples of the product in question must be analyzed and all four must meet the requirement.
Metal
Content
Mercury
< 0,1 ppm
Cadmium
< 1.0 ppm
Lead
< 5,0 7,5 ppm
We are aware of the standards current detection limits requires high quality measuring instruments which is now clarified in the requirement.

10. Draft criteria – proposed changes
O3 Plastic
Chlorine-based plastic may must not be used in primary batteries.
 Declaration from the manufacturer of the battery that the requirement is fulfilled. Appendix 2 may be used.
Ban on the use of PVC in the products (including labels) and their packaging
PVC-separators is typically being used between 1,5V cells. Other alternative types of plastic: PE, PE and nylon.

11. Draft criteria – proposed changes
O4 Packaging
The total proportion of post-consumer* recycled material in the primary packaging for the batteries must be at least 80% by weight.
Chlorine-based plastic must not be used in primary and secondary product packaging and any labels.
The primary packaging must be designed in such a way that dismantling is possible for all individual parts for waste sorting (e.g. cardboard, paper, plastic, metal) without using any tools.
* Post-consumer material is defined in accordance with ISO 14021: "Post- consumer/commercial" is defined as material created by households or product, which can no longer be used for the intended purpose. This includes return of material from the distribution chain.
The proposed requirement for use of minimum 80% post-consumer recycled material, apply to all types of materials e.g. paper, cardboard, plastic and so on, used in the primary packaging.

12. Draft criteria – proposed changes
O5 Consumer information on the battery and primary packaging
The battery must be marked in accordance with EN
The primary packaging must clearly state:
The types of energy-intensive appliances for which the battery is recommended in order to secure optimum use from the battery. This information must contain:
- Information on whether the batteries are suitable for appliances with high, medium or low energy drain.
- At least two pictograms showing examples of the types of energy-consuming appliances for which the batteries are suitable. Examples of high drain appliances: Camera flash, video camera, remote-controlled toy.
Date of manufacture or best before of the batteries (year and month).
Use of the Nordic Swan Ecolabel according to “Guidelines for using the Nordic Swan Ecolabel”
Nordic Ecolabelling are aware of that a requirement for” date of manufacturing” may lead to a “cherry picking” approach from the consumers, leaving a large amount of “old” batteries on the marked. Nordic Ecolabelling therefore propose to make it optional in the requirement to choose between “date of manufacturing” or “best before” as information on the primary packaging.

13. Draft criteria – proposed changes
O6 Sourcing of “conflict-free” minerals
The licensee and brand owner(s) must have a public conflict minerals policy and support the responsible sourcing of tin, tantalum, tungsten, gold, cobalt and their ores from conflict-affected and high-risk areas by:
Conducting due diligence in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas; and
Promoting responsible mineral production and trade within conflict- affected and high-risk areas for the identified minerals, as used in components of the products and in accordance with OECD guidance.
 The licensee and brand owner(s) shall provide a copy of their conflict mineral policy.
 The licensee and brand owner(s) shall describe their due diligence activities along the supply chain for the five minerals identified.
The EU regulation will be enforced in 2021.
Have a strict supply chain policy for responsible minerals sourcing that can be considered to cover at least 3TG and cobalt. Public
Have a process with the goal to identify smelters and refiners of at least 3TG and cobalt.
Be a part of an established multi-stakeholder program that works at supporting responsible sourcing programs for at least 3TG and cobalt

14. Draft criteria – proposed changes
O7 Sourcing of critical raw materials
The licensee and brand owner(s) must have a policy for the use of raw materials included in the EU’s list of critical raw materials in batteries. The list of critical raw materials can be found in appendix 6.
The policy must describe how the licensee and brand owner(s) works actively:
to phase out the use of critical raw materials in the long term
to recycle critical raw materials in the batteries
support recycling programs for collecting used batteries
minimize the use of critical raw materials in the future.
 The licensee and brand owner(s) must submit a written policy that describes how the licensee work actively to phase out/recycle any critical raw materials in batteries, support recycling programs for collecting used batteries and minimizing the use of critical raw materials in the future.
The list of raw materials produced by EU is based on the entire European market, not just the market for batteries. Therefore, some of the materials is not relevant for today’s battery production, but it might change in the future. Nordic Swan Ecolabelling requires the license holders to address the concerns regarding the use of critical raw materials.
Graphite is not possible to phase out in the short term.

15. Draft criteria – proposed changes
O9 Electrical testing
Minimum average duration (MAD)
The test conditions under which the batteries are tested must be in accordance with IEC :2015.
This requirement encompasses the testing of the operating time in various applications depending on the type of battery; see Table 1-5 below. The tables uses the designations in IEC :2015.
Each test includes at least nine eight batteries per size and model, and all nine eight must meet the requirements.
The battery must meet the minimum permitted operation time specified in Table 1-5 for the specific battery dimension. The battery must meet the test requirement for all applications specified in Table 1-5 for the specific battery dimension.
The new requirement for test of several electrical applications is based on requests from several stakeholders. The requirement ensure that batteries are good for all types of applications.
The RPS analysis shows that the use phase is very important in an LCA perspective. A short-lived use stage for batteries results in a higher environmental impact. A long lifespan of primary batteries results in potential resource savings and decreasing waste
The requirement to the minimum permitted operation time has been adjusted according to test-data from existing licensees (15 licenses) and external battery test

16. Draft criteria – proposed changes
O9 Electrical testing continue
Table 1: Household batteries, dimension LR20
Battery dimension
Application
Load
Daily period
EV (V)
Minimum permitted operating time
LR20
Portable lighting
2,2 Ω
4 min on, 11 min off for 8 h per day
0,9
20 h
Toy
1 h
0,8
26 25,5 h
Portable stereo
Current drain mA
2 h
18 17,5 h

17. Draft criteria – proposed changes
O9 Electrical testing continue
Table 4: Household batteries, dimension LR03
Battery dimension
Application
Load
Daily period
EV (V)
Minimum permitted operating time
LR03
Portable lighting
5,1 Ω
4 min on, 56 min off for 8 h per day
0,9 4h
Toy
1 h
0,8
200 min
Digital audio
50 mA
1 h on, 11 hr off for 24 h
20 h
Remote control
75 24 Ω
4 h 15 s per min 8 h per day
0,9 1,0
24 h

18. Draft criteria – proposed changes
O9 Electrical testing continue
Table 5: Household batteries, dimension 6LR61/LF22
Battery dimension
Application
Load
Daily period
EV (V)
Minimum permitted operating time
6LR61
Toy
270 Ω
1 h
5,4
22 h
Clock radio
620 Ω
2 h
60 53 h
Smoke detector*
Background: 10 kΩ
Pulse: 0,62 kΩ
1 s on, 3599 s off for 24 h day*
7,5
29 22 days
*According to part in IEC :2015
The requirement to the minimum permitted operation time has been adjusted according to test-data from existing licensees (15 licenses) and external battery test. Nordic Ecolabel agrees that it is difficult to set a requirement for the different battery dimension, e.g. LR 20 and the three applications, compared to the specific MAD-requirement in the IEC :2015, as these vary within the individual battery dimension. However, there is a lot of data behind the suggested MAD values.
Leakage
During testing, no leakage may occur.

19. Draft criteria – proposed changes
O10 Delayed discharge performance (shelf life)
The battery must achieve a delayed discharge performance after 12 month, or 13 weeks when using the high temperature test, of minimum % of the specific MAD limit listed in requirement O9 for each battery dimension and applications.
The test conditions under which the batteries are tested must be in accordance with IEC :2015.
Each test includes at least nine eight batteries per size and model, and all nine eight must meet the requirements.
The requirements concerning test laboratories are stated in Appendix 5.
 Complete test report.
 Documentation showing that the test laboratory fulfil the requirements stated in Appendix 5. Independent competent third party must confirm that the testing has been carried out in line with the requirement.
The new requirement supports the overall requirement to ensure a long battery operation time. The fewer batteries that are used, the lower the overall environmental impact of batteries.

20. Questions?

21. Closing Remarks
Please submit any comments to by August 12, 2018 at the latest
Documents containing proposed requirements for final draft is located here: