Joint industry statement on the impact of restricting primary batteries in Europe

15 September 2020

Orgalim together with 13 trade a...

Orgalim together with 13 trade associations consider the envisaged phase out of primary batteries incompatible with Europe’s goal for a carbon neutral economy. The signatory parties support the European Green Deal and Circular Economy Action Plan, and are committed to provide European consumers with truly sustainable solutions – based on proven positive impacts on both the environment and the European economy. Primary batteries have a vital role to play in a number of different battery applications and complement an increasing area of use of rechargeable batteries.


Primary batteries, today, provide growing levels of power while being smaller and using less materials than previous generation’s batteries. Since 2006, the environmental impact of primary batteries has even further decreased by implementing the collection obligation as set in the Batteries Directive 2006/66/EC. All waste primary batteries brought to a collection point are also effectively recycled. It is therefore with great concern that we see voices calling for a potential ban on primary batteries.

The European Commission is currently reviewing the Batteries Directive with a main focus on environmental sustainability. The proposed approaches and measures under discussion include a restriction or even a total prohibition of primary batteries. However, a recent assessment by the Öko Institute showed that even 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.

Furthermore, three life cycle assessments carried out by portable battery manufacturers demonstrate that primary batteries are more environmentally sustainable than other types of portable batteries when operated in low drain devices, the prime area of application for primary batteries. The lower and more efficient discharge level of primary batteries combined with the need for repeated recharging of secondary batteries makes primary batteries the best choice for low drain devices since these require lower power levels. Over 50% of the battery appliances market is focused on miniature, portable, lightweight, low drain applications and the prospects point to continued growth in this segment. The analysis of the Öko Institute indicates that a total prohibition of primary batteries would require scrapping 70% of today’s battery-powered devices, resulting in a considerable amount of waste.

In fact, many products have already transitioned to rechargeable batteries where this is both technically possible and advantageous from both an environmental and economic point of view (patient monitors, digital cameras, barcode scanners, uninterruptible power supplies (UPS), power tools, just to mention some). In general, high drain applications without long stand-by times before use, are best suited for rechargeable batteries. In low drain applications, however, primary batteries constitute a more sustainable solution than rechargeable ones. Thanks to their low self-discharge rate and durability, they are often the only option for a lifetime battery solution which in some applications (utility meters, smart city or environmental sensors and asset tracking devices) can go as far as almost two decades.

Furthermore, and contrary to persisting opinion, primary batteries cannot be compared to single use products such as certain plastics where no organised collection and recycling infrastructure exists. Primary batteries are energy sources and they have great impact on a vast number of essential applications and sectors using primary batteries. They are designed to be used many times in one or even multiple appliances, and in some cases for the entire use life of an equipment. Qualifying primary batteries as ‘single use products’ is hence misleading.

We also want to stress that not all primary batteries can be easily replaced by rechargeable batteries in any type of appliances. We caution against direct replacement ignoring the IEC (International Electrotechnical Commission) standards and the differences in voltage between primary alkaline batteries and lithium ion rechargeable batteries, for example. Additionally, many primary battery applications do not feature the technical infrastructure necessary for a rechargeable battery. Some equipment is not suitable to connect to the grid (such as asset tracking), to attach a solar panel to (inter alia IoT) or to send a maintenance crew to recharge the battery on a regular basis (highly distributed uses).

Finally, the specific technologies used in primary batteries are increasingly enabling the development of rechargeable designs and applications. Our concern is that by limiting or eliminating the well-established EU primary battery value chain, the potential for these key battery technologies would be at risk as a whole.

In Annex 1, we include a non-exhaustive list of sectors using primary batteries and for which an alternative does not exist or would impact negatively on the functioning of the product, sustainability or reliability, not to mention the design and manufacturing process.

The undersigned associations highlight that phasing out primary batteries will, in addition to the negative impact on the environment as outlined above, result in:

  • Unnecessary scrapping of an extreme number of devices currently powered by primary batteries resulting in a high number of products going to waste prematurely;

  • Impact on user experience, take for instance medical applications of patients in critical medical conditions or in older age who would be impacted by the burden of recharging to maintain therapy;

  • Extensive re-design, re-validation and re-registration of products to cater for:

    • More complicated battery management circuits including complete new mechanical designs;

    • More electronic parts and components (e.g. cables, chargers);

    • Existing manufacturing lines will become obsolete and new custom manufacturing lines will be required;

  • Peripheral recharging instruments (extremely inconvenient in some cases such as medical implants);

  • Loss of EU leadership in key technologies that are available for and are increasingly used in battery applications as a whole, whether primary or other.

In view of our support for the European Commission’s ambition to work toward a competitive, circular and sustainable environment and economy in the European Union, we want to caution against policy measures that result in more greenhouse gas emissions and waste, put at risk an existing European industry, create burdens and costs to various sectors, and negatively affect consumer expectations.

We call on the European Commission to take our industry data into account and to withdraw plans to generally phase out primary batteries in Europe.