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Heavy metals in end-of-life vehicles (updated list of exemptions)

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ID: 13006

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9 responses

European carmakers seek continued lead exemptions in vehicle components

Association des Constructeurs Européens d'Automobiles, 1 Jul 2022

ACEA requests continuation of exemptions allowing lead in aluminum alloys, copper alloys, and certain batteries. They argue the exemptions are essential to enable production and sale of cars in Europe. They want the review aligned with the broader ELV Directive review and criticize the short transition period for 24V batteries.
This avoids costly redesign and retooling while maintaining current production processes and supply chains.
Environmental and health groups lose faster phase-out of toxic lead in vehicles and waste streams.

BMW urges heavy metal exemptions and lower administrative burdens

Bayerische Motoren Werke Aktiengesellschaft, 24 Jun 2022

BMW requests continuing lead battery exemptions and a review date no earlier than 2025. They also oppose unnecessary numbering changes that create significant administrative and IT reporting costs.
BMW would avoid costly technical updates and ensure continued production of vehicles using lead-based batteries.
Environmental groups lose as the phase-out of hazardous lead in vehicles is further delayed.

European Aluminium urges clearer wording for automotive lead exemptions

European Aluminium AISBL, 28 Jun 2022

The organization proposes adding the word “wrought” to specific exemptions to distinguish between intentionally added lead and recycled scrap. They argue this change prevents overlapping categories and ensures that casting alloys remain eligible for recycling pathways.
The industry gains legal certainty and protects the continued recycling of aluminium scrap.
Recycling efforts and circular economy goals suffer if legal confusion hinders scrap processing.

ZVEI demands five-year extension for vehicle lead battery exemptions

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 27 Jun 2022

ZVEI requests maintaining lead battery exemptions for five more years. They reject restrictions on higher voltage batteries citing a lack of alternatives.
This avoids immediate bans on products and provides time for technical transition.

EUROBAT warns against banning lead batteries above 12 volts

Association of European Automotive and Industrial Battery Manufacturers, 24 Jun 2022

They request the next review happens no sooner than five years after the current one. They also want to remove restrictions on lead batteries above 12V due to insufficient technical evidence.
Industry would gain regulatory visibility and ensure a more consistent framework for future reviews.
Vehicle manufacturers and sustainability goals are harmed by the immediate ban on high-voltage lead batteries.

Lead industry association demands longer exemptions for vehicle batteries

International Lead Association, 27 Jun 2022

They request delaying the next review for at least five years for visibility. The group opposes removing 24V exemptions and demands a transition period for manufacturers.
Extended exemptions protect the industry's dominance in the low-voltage battery market.
Special purpose vehicle manufacturers lose market access without a sufficient transition period.

Consultation response

Federazione Nazionale Imprese Elettrotecniche ed Elettroniche, 1 Jul 2022

The Italian automotive and industrial battery industry, together wit European Association Eurobat, would like to provide its expert input to the Commission’s proposal for a Delegated Directive for the 11th adaptation to scientific and technical progress of exemption 5(b) of Annex II to Directive…

Consultation response

European Group of Automotive Recyclings Associations, 30 Jun 2022

Lead acid batteries are a perfect example of circular economy. Lead has a value and laed can be recycled until eternity for low costs. Transport is not problematic, costly or complex. Problems with lead will start when banned and value drops. Costs will be eveaded. Li-ion batteries are an…

Consultation response

Exide Technologies GmbH, 30 Jun 2022

Exide Technologies - a European producer of automotive and industrial batteries - would like to provide its expert input to the Commission’s proposal for a Delegated Directive for the 11th adaptation to scientific and technical progress of ‎exemption 5 of Annex II to Directive 2000/53/EC (ELV) for…