Environmental impact of electronic shelf labels: what is measured and what is a promise

No independent life cycle assessment yet shows that an electronic shelf label pays back, in emissions, the paper it avoids. The two studies we located are backed by interested parties and contradict each other. What is written into law is the battery: Regulation (EU) 2023/1542 sets removal, collection and labelling obligations with specific dates.

This page separates three layers that tend to be sold together: the paper no longer printed, the electronics and cells that are added, and what the law requires to happen to them. For the general framework on pricing and consumer rules, the regulation map is the place to start; only the environmental side is covered here.

The two paper sums, and who paid for each

The most quoted comparison is a University of British Columbia (UBC) report from September 2023, produced within its Sustainability Scholars programme. The document itself states that it was mentored by staff of Smart Label Solutions Inc. on behalf of the International EPaper Association (IEPA) and E-Tag Technology Corp.: manufacturers and promoters of e-paper. It concludes that one electronic label saves about 8.52 kg of CO₂ equivalent over eight years.

The sum has few parts, which is why it can be checked:

Item in the report	Value	What to look at
Emission per paper label (0.53 g)	0.00156 kg CO₂e	Per-tonne paper factor, averaged over three scientific papers; we did not see ink included
Electronic label lifetime	8 years	Assumption taken from an E Ink environmental report
Price changes	2 per day (5,840 in 8 years)	The assumption that weighs most on the result
Electronic label emission	0.59 kg CO₂e	E Ink figure for a 2.9-inch display module
Electricity	100% renewable (assumed)	Taken as given, not measured

The result is a subtraction: 5,840 paper labels come to 9.11 kg, the electronic label 0.59 kg, and the difference is 8.52 kg. The 0.59 kg figure is for an e-paper module. In what we could read of the report, battery, circuit board, antenna and housing are not added, and we did not see the radio gateway or installation counted either.

Against that stands the study Greenly carried out in 2023 for the Green Label Coalition, a consortium of paper-label companies. According to the case page, electronic labels had a higher impact than locally produced paper labels, mainly because of global manufacturing and transport. The page publishes no figures, functional unit, assumed lifetime or battery assumptions. What it says can be quoted; what it says cannot be checked.

So who is right? We don’t know, and we distrust anyone who claims to without showing the assumptions. A study funded by a paper seller and another funded by an e-paper display seller do not cancel each other out: both get read against the same list of questions.

The break-even depends on a number that is yours

Using the UBC paper value (0.00156 kg per printed label), the number of updates an electronic label needs to break even is a division. The table assumes different manufacturing emissions for the complete label, because the 0.59 kg covers the display only:

Manufacturing emission of the complete label (assumption)	Updates needed to break even	Equivalent over 8 years
0.59 kg CO₂e (display only, UBC figure)	about 380	about 47 a year
1.5 kg CO₂e	about 960	about 120 a year
3 kg CO₂e	about 1,920	about 240 a year

The 1.5 and 3 kg values are not data: they are hypotheses to show how the calculation moves. Even so, the pattern is clear. If each label changes only a few times a year, little paper is avoided and the manufacture of the label weighs heavily. If it changes daily, paper dominates. UBC assumes two changes a day, and that is an assumption, not a measurement of a real aisle.

What to do with this: there is no universal figure. Your store’s update frequency comes from your price history, and the cost of each paper-based change explains how to measure it. A well-designed pilot project can also record the paper prints that disappear and those that don’t, since not all of them will: promotional posters, headers or counter signage may stay on paper.

There are things neither report covers that someone will have to count: printing ink and toner, staff trips carrying paper, plastic holders, radio network power use, installation travel and replacement of faulty labels.

Retailers’ figures are company-scale numbers

Alcampo says it will avoid 1,843 km of paper strips and 8.4 tonnes of CO₂ with its 560,000 Hanshow labels, according to Alimarket (1 September 2026). Divided by label, that is about 15 g of CO₂ per label per year; over eight years, about 0.12 kg. That is less than the 0.59 kg UBC assigns to the display alone. It need not be a contradiction, because the article does not say whether the figure is gross (paper avoided) or net (after deducting manufacture). That is exactly the question to ask.

Lidl puts the saving from its UK rollout at more than 206 tonnes of carbon a year, attributed to less paper, packaging and ink (Sustainability Beat, 15 February 2024). Neither that source nor Alcampo’s gives a methodology. For the Spanish buyer, the supermarket sector analysis puts both in context with each chain’s public data.

The battery: what the datasheet says

The datasheets we reviewed mention one or two CR2450 lithium coin cells. Panasonic’s indicates about 6.2 g and 620 mAh per cell. On that basis, per 1,000 labels with one cell, one replacement cycle is 1,000 cells and about 6.2 kg; with two cells per label, 12.4 kg. The lifetime advertised in catalogues runs from 5 to over 10 years depending on model and daily updates, and the battery life explainer details how to convert that figure to yours.

That is a few kilos per store and many units across a large chain. And they are lithium cells, a different kind of waste from paper, with its own collection rules. So the honest comparison does not stop at “paper versus cell”: it asks how many cells actually reach a collection scheme.

Manufacturers are working on removing the cell, with results that need careful reading:

• Hanshow Nebular Lux (January 2022): a solar cell charges a lithium-manganese battery a quarter the size of the one in the Nebular series. The battery still exists; what changes is that it recharges. The announcement gives no savings figures.
• Pricer, SELECT project (September 2024): labels running on ambient light, with supercapacitors and recyclable circuit boards among the project partners, funded by the Eurostars programme. The article quantifies nothing.
• Rail power: Pricer’s Avenue system, cited in the battery explainer, moves the problem to the rail and the fixtures.

None of these routes has independent life cycle data in sight, and all three swap the cell for another component (solar cell, capacitor, rail) with its own footprint.

What Regulation (EU) 2023/1542 says, and from when

The Batteries Regulation entered into force on 17 August 2023 and generally applies from 18 February 2024 (European Commission). The obligations that affect a label’s cell arrive in stages:

Date	What changes	Article
18 August 2025	All batteries carry the separate collection symbol. The extended producer responsibility chapter applies	13.4 and 96
18 August 2026 (or 18 months after the implementing act, if later)	General information label; non-rechargeable batteries also minimum average duration and the “non-rechargeable” marking	13.1 and 13.3
18 February 2027	Portable batteries removable and replaceable by the user; QR code on all batteries	11 and 13.6
31 December 2027	Waste portable battery collection: 63%	59
31 December 2030	Collection: 73%	59

We have not checked whether the labelling implementing act, which the Commission was due to adopt before 18 August 2025, was published on time; the August 2026 date being effective depends on it. The recycling targets concern what happens after collection: 65% average weight for lithium batteries at the end of 2025 and 70% at the end of 2030, and lithium recovery of 50% at the end of 2027 and 80% at the end of 2031 (Annex XII). They are targets per recycling facility, not per cell, and a small batch of CR2450s mixed with other batteries contributes little to them.

The carbon footprint (Article 7) does not apply: it is only required for electric vehicle batteries, rechargeable industrial batteries above 2 kWh and light means of transport batteries. If a brochure gives a footprint for a label’s cell, it is a voluntary figure with no official method behind it.

Article 11 applied to a label

The text obliges “any natural or legal person who places on the market products incorporating portable batteries” to ensure they are readily removable and replaceable by the end user throughout the product’s lifetime. “Readily removable” means it can be taken out with commercially available tools, without specialised tools (unless supplied free with the product), without proprietary tools, and without thermal energy or solvents. In addition:

• The product must come with removal and replacement instructions, permanently available online.
• The battery must be available as a spare for at least five years after the last unit of the model, at a reasonable, non-discriminatory price (Art. 11.7).
• Software may not be used to prevent replacement with another compatible battery (Art. 11.8).

The hard part is knowing whether a label is covered. The definition of “portable battery” (Art. 3.9) requires it to be sealed, weigh 5 kg or less and not be specifically designed for industrial use. A 6 g coin cell meets the weight and format; the doubt is whether a shelf label, being equipment for commercial use, makes its cell “industrial”. We found no official source that settles it.

The exceptions don’t name it either. Article 11 exempts appliances for environments with regular splashing intended to be washed (only where needed for safety) and some medical devices, and paragraph 3 exempts cases requiring continuous power supply or data integrity. Delegated Regulation (EU) 2026/1770, dated 14 July 2026 and published on 22 October, rewrites the list in paragraph 2, which now holds eight cases. The two already there stay (wet-environment appliances, now extended to wearables, and certain professional imaging, radiotherapy and in vitro diagnostic medical devices), and six are new: very small or sealed wearables, electric toys until 31 July 2030, wireless food thermometer probes, products for explosive atmospheres, subcutaneous drug delivery systems and telematics for agricultural and construction machinery. It enters into force twenty days after publication, around 11 November 2026. Shelf labels do not appear.

A practical consequence for the cold chain: the Commission guidance, as summarised by a law firm, warns that an IP rating alone is not enough to claim the wet-environment exception, and that the manufacturer must document why removal by the user would be unsafe. A label in a cold room with condensation is not automatically exempt.

End of life: equipment, batteries and who pays

A label is electrical and electronic equipment; the Regulation itself refers to the definition in Directive 2012/19/EU. It has two waste streams: the equipment and the cell removed from it. Under Article 59, producers of portable batteries, or their collective scheme, must collect free of charge batteries removed from waste electrical and electronic equipment, in addition to those handed in at collection points. The obligation is theirs, not the retailer’s, but the retailer is the one holding the removed labels in the stockroom.

Transposition is national. In Spain, for instance, the Ministry for the Ecological Transition put to public consultation, from 30 June to 3 September 2026, a draft royal decree that would implement the Regulation and repeal Royal Decree 106/2008. According to PwC’s analysis, it would also apply to batteries incorporated in equipment, create a dedicated section in the Producers Register, oblige portable battery producers to act collectively and amend Royal Decree 110/2015 on electrical equipment. It is a draft: we have not found its approval. If you operate in another Member State, check that country’s implementing law and producer register.

What this means when buying, in two lines: in the tender (the RFP template has a battery section) ask in writing who is registered as producer, who collects labels and cells at end of life, at what cost and with what proof. And in the vendor checklist, record the answer on Article 11 with its basis: compliant, or exception applied, and which.

Five questions before believing an environmental figure

1. What does the calculation boundary include: only the display, or also cell, board, housing, gateway and transport?
2. How many updates per day or year per label are assumed, and where does that rate come from?
3. What lifetime is assumed, and who has verified it in a real installation?
4. Is the figure gross (paper avoided) or net (after manufacture)? With which electricity mix?
5. Who commissioned and paid for the study, and is the method published so it can be repeated?

With those five answers, a figure from Lidl, Alcampo or a brochure becomes comparable. Without them, it is a press item.