EU Battery Regs (5): The European Electronic Exchange System

The information in this post is now superceded.
NOTE – this blog post relates to a 2023 reserach project which was analysing the evolving EU Batteries Regulation.

The EU is soon to adopt new regulations for batteries and battery waste. For electric vehicle, and industrial batteries, producers will need to adopt and develop systems that can supply information into an EU centrally-managed data space, termed the European Electronic Exchange System (EEES) for battery information.

This article explains the likely requirements, based on currently-available information. Please note, that while general shape of the regulation and it’s requirements is reasonably well known, until the regulation is officially published and comes into force, these information requirements may change. See ‘regulatory background’ below for more detail.

The EEES, and its role in the battery information ecosystem

The European Electronic Exchange System (EEES) for battery information is one of three new information systems, proposed under COM/2020/798, to improve the transfer of information between different stakeholders in the battery value chain. In addition to the EEES, the regulation also introduces battery passports and QR smart labels, with the regulations mandating interoperability and integration between these systems and the EEES.

While these are generally presented as three separate systems in separate sections of the regulation, in practice they characterize different subsets of functionality of a larger battery information ecosystem, that transfers (and makes available) information across a manufacturer’s ecosystem. In effect, each system becomes a portal into a common information environment. Importantly though, battery passport and EEES functionalities are only required for electric vehicle, industrial, and light means of transport batteries,, whereas the QR smart label functionalities will be required for all battery types.

About the European Electronic Exchange System

According to the EU (Article 64(2)), the EEES is being set up to facilitate easier sorting and searching of information and data, and is intended to (Article 64(1a)):

(a) support market surveillance authorities carry out their tasks and responsibilities
(b) provide public with battery information sheets, and information on the sustainability and safety of batteries placed on the market.
(c) provide the commission and accredited remanufacturers, second-life operators and recyclers with up-to-date information about those batteries.

The EEES will act as a “regularly updated database for all batteries falling under this regulation” (Article 64(2)). As per Article 64(4), the EEES will also be used by member states to report production, waste collection and recycling efficiency information to the commission. In the context of battery passports, the role of the EEES is focused on the sharing of information at the level of a given battery model or type. However, the wider system likely to have some asset-specific traceability and reporting, given its integrated nature with manufacturer’s battery passport systems (Article 65(3)), and the need to report organisation-level performance of waste management for compliance purposes, in addition to the product-level information discussed below.

As per Article 64(3), economic operators (that place applicable batteries in the market) must put in place systems that can supply the necessary information (detailed below) “electronically in a machine readable format using interoperable and easily accessible data services”. The architecture/design of the EEES is not yet defined, nor has the EU specified the format that information should be shared in, but they will do so by 31 December 2024 (Article 64(5)), along with “rules for accessing, sharing, managing, exploring, publishing and reusing of the information and data in the system”. As per Article 64(2), the EEES will be based on “open standards for third party use”. The end goal is a system providing access to information about all (relevant) batteries, from all economic operators, that is easily “sortable and searchable” (Article 64(3).

The EEES will, based on the current regulatory scope, collect information pertaining to industrial, electric vehicle, and light means of transport batteries. Economic operators (who place relevant batteries onto the market or into service) will be responsible for supplying this information, in the format that the EU has yet to specify. This information will be required from 1 January 2026.

What product-related information goes into the EEES?

Article 64(2) (cross referencing Annex XIII) sets out the information that must be provided to the EEES by each economic operator. Annex XIII groups this information into three classes, based on who it is expected will be permitted to access the information from the EEES (albeit recognizing that, as per Article 64(5)(c), complete rules for “accessing, sharing, managing, exploring, publishing and reusing” the information contained within / accessible via the EEES will not be established until 31 December 2024). In all cases, this information must be available by 1 January 2026.

Information to be stored and made available in the publicly accessible part of the system by the economic operator that places a battery on the market

Annex XIII(1)(a) Battery manufacturer;
Annex XIII(1)(b) Battery type;
Annex XIII(1)(c) General description of the model, sufficient for it to be unequivocally and easily identified, including the date of placing in the market;
Annex XIII(1)(d) Manufacturing place and date;
Annex XIII(1)(e) Battery composition, including critical raw materials;
Annex XIII(1)(f) Carbon footprint information in the units indicated in the relevant implementing measure(s);
Annex XIII(1)(g) Information on responsible sourcing as indicated in the relevant implementing measure(s);
Annex XIII(1)(h) Recycled content information as indicated in the relevant implementing measure(s);
Annex XIII(1)(i) Rated capacity (in Ah);
Annex XIII(1)(j) Minimal, nominal and maximum voltage, with temperature ranges when relevant;
Annex XIII(1)(k) Original power capability (in Watts) and limits, with temperature range when relevant ;
Annex XIII(1)(l) Expected battery lifetime expressed in cycles, and reference test used;
Annex XIII(1)(m) Capacity threshold for exhaustion (only for EV batteries);
Annex XIII(1)(n) Temperature range the battery can withstand when not in use (reference test);
Annex XIII(1)(o) Period for which the commercial warranty for the calendar life applies;
Annex XIII(1)(p) Initial round trip energy efficiency and at 50% of cycle-life;
Annex XIII(1)(q) Internal battery cell and pack resistance;
Annex XIII(1)(r) C-rate of relevant cycle-life test.
Annex XIII(1)(ra) Status of the battery (first life, waste, repaired, repurposed, recycled).

The part of the system that shall be accessible only to accredited remanufacturers, second-life operators and recyclers shall contain:

Annex XIII(2)(a) Detailed composition, including materials used in the cathode, anode and electrolyte;
Annex XIII(2)(b) Part numbers for components and contact details of sources for replacement spares;
Annex XIII(2)(c) Dismantling information, including at least:
- Exploded diagrams of the battery system/pack showing the location of battery cells,
- Disassembly sequences,
- Type and number of fastening techniques to be unlocked,
- Tools required for disassembly,
- Warnings if risk of damaging parts exist,
- Amount of cells used and layout;
Annex XIII(2)(d) Safety measures

The part of the system that is accessible only to notified bodies, market surveillance authorities and the commission

Annex XIII(3)(a) Results of tests reports proving compliance with the requirements laid out in this Regulation, and its implementing or delegated measures.

Who is responsible for the product-related information in the European Electronic Exchange System?

We hope that this information is useful to build awareness of the future information requirements for the EEES. However, we present this information (January 2023) without guarantee to its accuracy, given the transient nature of the EU regulatory development process, and the complexity of the regulations. Those seeking to understand the regulations in more detail are encouraged to read the original commission text and parliamentary amendments in more detail.

Regulatory Background

This European Regulation exists within a process of three stages and three sets of actors:

The European Commission (the EU’s politically independent executive arm) is responsible for drawing up proposals for new European legislation, and implementing these once agreed upon by the European Parliament and the Council of the EU. The European Commission (EC) first published its Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020 (source), on 10 December 2020.
The European Parliament (the EU’s elected governing body) is the EU’s lawmaking arm, responsible for passing EU laws, together with the Council of the EU. On 10 March 2022 (source), the European Parliament agreed to the council proposal, with amendments (sou r ce), principally to raise the level of ambition in the legislation.
The Council of the EU contains representatives of each member state in the EU, responsible for committing their respective governments to any agreed actions in EU meetings, including the adoption of new laws. On 9 December 2022 (source) it was announced that inter-institutional negotiations, between the commission, parliament, and the council of the EU had resulted in provisional agreement, that must now be formally approved by the commission and parliament.

The above information is based upon the amendments made by the European Parliament, as the content of the third-stage negotiations has not yet been published. Progress of this regulation can be tracked via the EU’s legislative train and procedure file pages.