Skip to main content
  3. Non-rechargeable portable batteries 001

Public consultation on Non-rechargeable portable batteries 001

August 12 – October 6, 2025

During the consultation period, Nordic Ecolabelling gives you the opportunity to comment on our proposal for new criteria for Non-rechargeable portable batteries.

Nordic Ecolabelling are revising the requirements for 001 non-rechargeable portable batteries, which includes non-rechargeable portable batteries in accordance with the definition given in the European Union's Battery Regulation (EU) 2023/1542. You are welcome to respond to the proposal no later than Monday 6th of October 2025.

Consultation documents

How can response be sent in?

We look forward to receiving your response via this form: RESPONSE FORM. You can give your response in English or your Nordic language. 

A compilation of the consultation responses, with answers from Nordic Ecolabelling and the names of the responding organisations, will be published on the Nordic Swan Ecolabel web page.

Most important issues

Nordic Ecolabelling would like to have comments on the complete criteria set, but would like to highlight the following points. 

  • Updated requirement O3 Excluded substances. Per- and polyfluoroalkyl (PFAS) substances are added as an excluded substance in this generation of criteria. The ban of chlorine-based plastic remains the same as in generation 5. The requirement has changed name from "Plastic" to "Excluded substances". Nordic Ecolabelling welcomes feedback on the practical feasibility of implementing this requirement.
  • Updated requirement O6 Responsible sourcing of mineral raw materials.
    All licensees, regardless of turnover, must now have a Due diligence management system according to the new EU Batteries Regulation (EU) 2023/1542. Further, all smelters and refiners now must be verified by a relevant third party, such as the Responsible Mineral initiative (RMI). The requirement has been stringent to include all mineral raw materials. Generation 5 only included the conflict minerals tin, tantalum, tungsten, gold and cobalt. Nordic Ecolabelling welcomes feedback on the practical feasibility of implementing this requirement.
  • New requirement O12 Energy consumption. Energy consumption data must be reported using the specified reporting sheet. Nordic Ecolabelling invites feedback regarding reporting data and the feasibility of submitting the required data. 
  • New requirement O13 Energy source – fossil fuels. The use of fossil oil and coal is proposed to be prohibited in battery production, and a maximum threshold of 15 % natural gas usage is introduced. Nordic Ecolabelling welcomes feedback on both the proposed limit and the practical feasibility of implementing this requirement. 
  • New requirement O14 Renewable electricity. A minimum limit of 20 % of the annual electricity used in the battery production must be generated on-site from renewable sources. Nordic Ecolabelling welcomes feedback on both the proposed limit and the practical feasibility of implementing this requirement. 

For more information about the consultation process in general, read here.

For specific questions regarding the consultation, please contact product manager Elin Östberg, elin.ostberg@svanen.se. Please note that consultation responses should not be submitted via this email address.