The technology sector points to a gap in the EU Environmental Omnibus – batteries at stake
The Digital Poland Association is calling on the Polish government to take action to expand the EU Environmental Omnibus package to include issues related to batteries, including rules on their replaceability. According to the technology sector, this is one of the key factors affecting the actual lifespan of electronic devices and, consequently, the scale of e-waste.
In its position submitted to the Ministry of Climate and Environment, the Association emphasised that while current regulatory proposals focus on environmental goals, they fail to address one of the most important factors determining product durability – the design and functioning of batteries.
Batteries and the real durability of devices
“Batteries are one of the key components of electronic devices and in practice often determine their lifespan. If we truly want to reduce e-waste, we must look at how regulations affect the durability of the entire product, not just a single component,” said Dominik Dobek, expert at Digital Poland Association.
The technology sector points out that introducing rigid requirements for battery replaceability–without taking into account technological specifics—may produce effects opposite to those intended.
As Digital Poland Association highlights in its position, in the case of modern, advanced devices, requiring easy battery replacement often entails design trade-offs, such as reduced resistance to damage, limited sealing, or increased susceptibility to failure. As a result, this may shorten product lifecycles and increase e-waste, the organisation warns.
“Poorly designed regulations may make devices less durable, which means more frequent replacement and greater environmental pressure,” adds Dominik Dobek.
Broader regulatory risks
The Digital Poland Association also indicates that some proposals within the Environmental Omnibus package may lead to unintended economic and operational consequences.
One of the key challenges is the risk of distorting the level playing field. The proposed solutions may, in practice, impose a greater burden on manufacturers operating within the European Union, while entities from outside the EU may function in a less restrictive regulatory environment.
The technology sector also raises implementation concerns, including provisions on battery labelling (e.g. QR codes). In their current form, these may significantly complicate supply chain management and device servicing—especially for products where the battery is only one of many components.
“Environmental regulations must be not only ambitious but also workable. Otherwise, they will generate costs and barriers without delivering real environmental benefits,” emphasises Dominik Dobek.
A call for a realistic approach
For this reason, the technology sector calls for battery-related issues to be included in the Environmental Omnibus package, but in a way that reflects technological realities. A flexible approach is essential, allowing for exceptions where battery replaceability negatively impacts safety, durability, or device functionality.
Experts from the Digital Poland Association stress that they do not question the direction of the changes, but call for greater precision and stronger consideration of market practice.
“Good regulations are those that work in reality, not only on paper. That is why we need solutions that both support the environment and enable the development of modern technologies,” concludes Dominik Dobek.