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Association of European Automotive and Industrial Battery Manufacturers

EUROBAT

EUROBAT represents European manufacturers of automotive, industrial and energy storage batteries, comprising over 90% of the European battery industry.

Lobbying Activity

EUROBAT Urges Harmonized Rules for the Battery Circular Economy

28 Oct 2025
Topic — The Circular Economy Act aims to boost EU economic security through sustainable production and recycling.
Message — They request the Act align with existing battery laws to avoid duplicating requirements. They want unified standards for shipping waste to make recycling easier across borders. The group calls for a strict definition of recycled materials to stop illegal exports.123
Why — Unified rules would lower administrative costs and secure the supply of critical minerals.45
Impact — Illegal exporters lose revenue as stricter controls block the unauthorized flow of materials abroad.6
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Battery industry backs delay and alignment of EU rules

18 Jul 2025
Topic — Proposal to postpone battery due diligence obligations and align them with horizontal directives.
Message — The associations support postponing due diligence obligations while calling for rules to be aligned with existing sustainability directives. They request the swift publication of guidelines and the timely establishment of national verification bodies.123
Why — This alignment would reduce regulatory uncertainty and prevent costly duplication of reporting requirements.45
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Meeting with Maroš Šefčovič (Commissioner) and

11 Jul 2025 · Implementation dialogue on customs legislation - Rules of origin

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)

9 Jul 2025 · Roadworthiness package

Meeting with Jens Gieseke (Member of the European Parliament) and IVECO GROUP N.V. and

4 Mar 2025 · Austausch zu EU Politik

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

EUROBAT, the Association of Battery Manufacturers welcomes the inclusion of battery technologies as net-zero ‎technologies in the draft list of final products and specific components considered to be primarily used for the ‎production of net-zero technologies. ‎In the annex for the final products and main specific components, battery technologies are mentioned in ‎battery and energy storage technologies. As explained in the document submitted as attachment to the public consultation, the table needs to corrected: according to the new Batteries Regulation, packs and modules are not the final ‎products - they should be listed as main specific components only. Batteries, as defined in Articles 3.11, 3.12, 3.13, 3.14 & 3.15 of the new Batteries Regulation, should be considered as the final product.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

EUROBAT, the Association of Battery Manufacturers welcomes the inclusion of battery technologies as net-zero ‎technologies in the draft list of final products and specific components considered to be primarily used for the ‎production of net-zero technologies. ‎ In the annex for the final products and primarily used components, battery technologies are mentioned in ‎battery and energy storage technologies. As explained in the document submitted as attachment to the public consultation, the table needs to corrected: according to the new Batteries Regulation, packs and modules are not the final ‎products - they should be listed as primarily used components only. Batteries, as defined in Articles 3.11, 3.12, 3.13, 3.14 & 3.15 of the new Batteries Regulation, should be considered as the final product.
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Meeting with Beatriz Yordi (Director Climate Action)

22 Jan 2025 · Future of battery manufacturing in the EU

Meeting with Elena Nevado Del Campo (Member of the European Parliament)

13 Dec 2024 · Industria nacional de baterías

Meeting with Bruno Tobback (Member of the European Parliament)

20 Nov 2024 · Batteries

EUROBAT warns complex waste codes will stifle battery recycling

8 Nov 2024
Topic — The Commission is updating the European List of Waste for batteries.
Message — EUROBAT requests a simpler, easy-to-use list with fewer waste codes. They argue the current proposal is too technical and complex for practical application.12
Why — Streamlined codes would lower administrative burdens and prevent licensing delays.3
Impact — Regulators may lose granular data required for precise waste tracking.4
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EUROBAT Urges Simplified Rules for Battery Recycling Reporting

18 Oct 2024
Topic — New methodology for calculating and verifying battery recycling efficiency and material recovery rates.
Message — EUROBAT requests streamlining reporting templates and removing unnecessary location-based data. They suggest adding rows for dismantled parts to improve efficiency calculation accuracy and seek better visibility for substance exclusion rules.12
Why — This would reduce administrative burdens and prevent misleadingly low recycling efficiency scores.3
Impact — Environmental watchdogs lose the ability to track the geographic destination of recycled materials.4
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Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

EUROBAT urges realistic life-cycle metrics for electric batteries

28 May 2024
Topic — Rules for calculating and verifying the life-cycle carbon footprint of electric vehicle batteries.
Message — Manufacturers want battery life measured by technical performance rather than marketing warranties. They also insist that sensitive business data should only be shared with authorized private auditors.12
Why — This allows companies to report lower footprints and protect their industrial secrets.34
Impact — Market surveillance authorities lose access to background data needed to verify compliance.5
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Response to Format of the carbon footprint declaration for batteries

28 May 2024

EUROBAT, the Association of Manufacturers of Automotive and Industrial Batteries, welcomes the upcoming ‎adoption of a methodology for determining the carbon footprint of electric vehicles. EUROBAT maintains its ‎support for the introduction of a carbon footprint declaration, performance classes and maximum thresholds to ‎promote green batteries made in Europe. ‎ Nonetheless, EUROBAT considers that several elements of the proposed format of the carbon footprint ‎declaration need to be amended to ensure that it can be applied in practice and its enforcement properly ‎monitored by notified bodies, and that it properly reflects the climate impact and benefits of the battery value ‎chain, also in line with our proposed changes to the draft delegated act on the methodology, as laid out in the attached position paper. Specifically, the carbon footprint declaration should include a reporting period, or date of validity of the label, ‎reflecting the duty to re-calculate the carbon footprint of a battery when it increases by more than ‎‎10%. ‎ Also, it should be noted that a resolution expressed in grams of CO2-equivalent/kWh is not defined, and no information is ‎available on how it should calculated and verified, neither in the 2023 draft JRC Report nor in other ‎official documents. ‎
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Meeting with András Gyürk (Member of the European Parliament)

25 Mar 2024 · Overview of EU Industrial Policy

Battery association EUROBAT urges removal of battery rules

9 Nov 2023
Topic — The European Commission is revising rules for vehicle design and end-of-life recycling.
Message — EUROBAT requests removing battery substance restrictions from the proposed vehicle circularity regulation. They suggest moving lead battery reviews to the Batteries Regulation to ensure consistency.12
Why — This would reduce administrative burdens and eliminate risks of overlapping, contradictory regulations.34
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Meeting with Pascal Canfin (Member of the European Parliament) and SMEunited aisbl and Novonesis A/S

8 Nov 2023 · Green Deal

Response to European Critical Raw Materials Act

30 Jun 2023

EUROBAT, the leading association of European automotive and industrial battery ‎manufacturers,‎ supports the EU Commission's Critical Raw Materials Act in their urgency of action to address the 2030 risk of raw materials bottlenecks for clean energy technologies. In anticipation of the upcoming negotiations between the European Commission, the ‎European Parliament and the Member States, EUROBAT wishes to convey its vision for a ‎Critical Raw Materials Act that effectively supports battery manufacturing in the EU. ‎ ‎1.‎ Accelerate permitting procedures: implement measures to enhance the pace of national ‎permitting processes while upholding environmental standards by allowing parallel ‎processes, allocating additional local resources and establishing clear timelines for ‎decision-making.‎ ‎2.‎ Make funding available for EU battery projects, including battery research, ‎manufacturing, extraction, refining and recycling, and provide certainty to investors, ‎ultimately facilitating an industrial transformation through direct lines of funding.‎ ‎3.‎ Recognise certification schemes within the CRMA, including third-party schemes that ‎meet sustainability criteria. Similarly, it is crucial to enhance Europe's strategic ‎partnership strategy for raw materials by developing a clear plan to address ‎dependencies and expedite actions in regions with the necessary capabilities.‎ ‎4.‎ Ensure consistency and coherence with other legislation. It is vital to mitigate the risk of ‎uncoordinated policies obstructing its goal of achieving climate neutrality.‎
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EUROBAT Urges EU to Boost Battery Manufacturing and Funding

27 Jun 2023
Topic — The Net Zero Industry Act aims to increase domestic manufacturing of clean energy technologies.
Message — EUROBAT requests expanding the scope to active materials and securing direct EU-level funding. They also request preserving the one-stop shop for permits to accelerate project approvals.123
Why — Manufacturers would secure direct subsidies and faster approvals for a wider range of battery projects.45
Impact — Environmental groups lose if safety rules for lithium are softened to favor industrial benchmarks.67
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Meeting with Véronique Trillet-Lenoir (Member of the European Parliament, Shadow rapporteur) and European Trade Union Institute and

25 May 2023 · Revision of CAD & CMRD

EUROBAT Urges Higher Lead Limits and a Five-Year Transition

26 Apr 2023
Topic — The consultation concerns revising binding exposure limit values for lead in European Union workplaces.
Message — The association requests raising the occupational exposure limit to 50 µg/m³. They also propose a transitional period until 2030 for biological limits.12
Why — This would prevent factory closures and significantly reduce compliance costs for the battery industry.34
Impact — Workers face prolonged exposure to higher lead levels due to the requested implementation delays.5
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Response to European Critical Raw Materials Act

25 Nov 2022

The European automotive and industrial battery industry supports the proposal for a Critical Raw Materials Act to ensure a sustainable supply of raw materials in the EU. Europe relies heavily on batteries to decarbonise mobility, energy systems and other sectors. The battery industry is investing substantial resources in further developing battery technologies which deploy less significant percentages of lithium, nickel and cobalt, though such raw materials remain fundamental components of batteries and their use is set to increase steadily through 20502. Considerable progress is being made to reduce Europes dependency on third countries for raw materials and according to the European Battery Alliance there are projects being developed in the EU for 310GWh of cell production per year. But Europe remains highly exposed to raw materials trade flows disruptions as today less than 3% of battery production happens in Europe. Securing the supply of raw materials is not only of strategic importanceit would also allow European businesses to gain from the growing market for battery cells, which is expected to reach 360 billion globally in 20303. Against such context, EUROBAT suggests a truly successful European Critical Raw Materials Act needs to support the further development of clean technologies making use of raw materials. Batteries in particular are set to represent a key growth vector of raw materials demand and the EU Raw Materials Act needs to incorporate both a domestic and international dimension as follows. Get the policy framework right at home - Policy consistency across pieces of legislation. A stable and fit for purpose regulatory framework is the precondition for investing in EU raw materials mining, processing and recycling capacity. Inconsistencies with other pieces of legislation should be addressed, including the proposed classification as toxic of three lithium salts. The European Critical Raw Materials Act should avoid overregulating aspects of the battery value chain which are already addressed by other pieces of legislation. In particular, the Batteries Regulation proposal already introduces a robust sustainability framework for batteries, including ambitious recycled content and recycling efficiency targets. - Consider strategic raw materials demand sectors. Batteries are of critical importance for the success of the EU Green Deal and the competitive environment battery manufacturers operate in has significantly evolved since the first Battery Action Plan was developed in 2018. The European Critical Raw Materials Act offers the opportunity to update the EU Battery Action Plan and articulate the steps Europe should take to further support batteries roll out through an enhanced EU raw materials value chain. Act assertively internationally - A level playing field across the board. The battery market is inherently global. Though a subsidy race is not a desirable outcome, the Raw Materials Act should leverage the EU defensive and offensive trade measures and support European companies investing in highly sustainable and environmentally friendly batteries and other raw materials-based products, in the EU and in third countries. - Expand and strengthen the EU raw materials partnerships. Europe has the highest environmental and human rights protection standards in the world. The European Critical Raw Materials Act should strengthen the cooperation with like-minded jurisdictions and define project pipelines across the raw materials value chain that respect European values.
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EUROBAT warns against banning lead batteries above 12 volts

24 Jun 2022
Topic — Updating the list of heavy metal exemptions for end-of-life vehicle parts.
Message — 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.12
Why — Industry would gain regulatory visibility and ensure a more consistent framework for future reviews.34
Impact — Vehicle manufacturers and sustainability goals are harmed by the immediate ban on high-voltage lead batteries.56
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EUROBAT rejects including battery production in new emissions rules

23 Jun 2022
Topic — Revision of EU industrial emissions legislation to improve environmental performance and sustainability.
Message — EUROBAT rejects extending the directive's scope to lithium-ion battery manufacturing and mineral extraction. They oppose using the strictest emission levels as the basis for permits.12
Why — Maintaining the current scope prevents longer permitting times and preserves investment predictability.3
Impact — Local communities and environmentalists lose standardized transparency regarding the hazardous chemicals used.4
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Response to Sustainable Products Initiative

21 Jun 2022

EUROBAT welcomes the already-tabled Ecodesign for Sustainable Products Regulation and re-‎confirms its full support for the creation of a fully-decarbonised economy by 2050. It is important ‎to further optimise products and create a circular economy ecosystem through more efficient ‎common standards that will help to reach the environmental objectives.‎ We commend the replacement of the former Ecodesign Directive with a Regulation that will ‎become immediately enforceable as law in all Member States at the same time. In this sense, ‎ensuring effective and equal enforcement throughout the Member States is paramount to assure a ‎level playing field in the EU.‎ There are, however, some implications in the proposal that we would like to address in order to ‎raise some concerns.‎ Double regulation should be avoided as it will result in a duplication of efforts. There is no need to ‎over-regulate products that are already covered under “product-specific” legislation that covers ‎the whole life-cycle, from mining to recycling. In this sense, consistency with existing requirements ‎under other EU laws (e.g. Batteries Regulation) is needed to avoid the duplication of efforts in ‎providing information. Creating an over-regulation scenario will hinder industry growth and ‎endanger the achievement of the 2050 goals. ‎ Similarly, consistency and alignment between the tabled proposal with the new requirements and ‎overarching pieces of legislation (e.g. REACH, SCIP databases, RoHS Directive, etc.) must be ‎ensured in order to avoid duplications, double-efforts and industry burdens. Regarding chemicals, ‎they are already covered by several legislative files. In this sense, we would like to highlight Recital ‎‎22 from the current proposal which states that “this Regulation also should not result in the ‎duplication or replacement of restrictions of substances covered by Directive 2011/65/EU of the ‎European Parliament and of the Council, which has as its objective the protection of human health ‎and the environment, including the environmentally sound recovery and disposal of waste from ‎electrical and electronic equipment.”‎ Moreover, this proposal brings a notion of “substances of concern” (SoCs) to cover “those related ‎to circular economy, substances having a chronic effect for human health or the environment ‎‎(Candidate list in REACH and Annex VI to the CLP Regulation) but also those which hamper ‎recycling for safe and high quality secondary raw materials” (Chemicals Strategy for Sustainability, ‎p2). This definition entails that “substances of Concern” will include: all substances on the ‎Candidate List; all substances classified for chronic effect for human health and the environment; ‎and, all substances that hamper the re-use and recycling of materials. Therefore, it is likely that ‎many metals and their compounds will fall under this definition of SoCs as most metals have a ‎chronic hazard classification of some sort. This will create an administrative burden for the ‎industry and an increase in resources, as a raft of delegated acts will be developed to address ‎different product groups, setting new information requirements regarding the presence of SoCs. ‎As mentioned above, it is crucial for the industry that the new requirements will not transform into ‎a duplication of obligations. Consistency and alignment with other pieces of legislation are ‎paramount. ‎
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Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

21 Mar 2022

EUROBAT is the leading association for European automotive and industrial battery manufacturers, ‎covering all battery technologies, and has more than 50 members. The members and staff work ‎with all policymakers, industry stakeholders, NGOs and media to highlight the important role ‎batteries play for decarbonised mobility and energy systems as well as all other numerous ‎applications.‎ EUROBAT welcomes the call for evidence for an impact assessment in view of the revision of the ‎Chemical Agents Directive (CAD). ‎ EUROBAT has developed internal guidelines to lower blood lead concentrations in workers of its ‎member companies. ‎ EUROBAT launched its Blood Lead Mitigation Programme in 2000.‎ Participation in the programme is mandatory for members of EUROBAT. The programme ‎establishes a target of no employees with measured blood lead exceeding 200 µg/L by the end of ‎‎2025, down from a target of 250 µg/L by the end of 2019. ‎ The programme only applies to battery manufacturing companies that are members of EUROBAT ‎and therefore does not ensure harmonised protection against lead exposure for all other activities ‎and businesses where lead exposure is possible in the EU. ‎ The current binding limit values were set in 1982 with a 4-year transposition period and are no ‎longer reflective of scientific evidence of health effects at the workplace ‎ or the current ‎performance of industry in managing lead exposures.‎ EUROBAT therefore supports the downwards revision of the binding occupational exposure limit ‎‎(OEL) and biological limit value (BLV) in EU legislation for lead and its inorganic compounds but ‎recommends adopting a stepwise approach that initially reflects industry best practice but ‎ultimately delivers a new BLV that is fully protective of health in every member state. ‎ Monitoring the BLV (lead in blood) must be the primary method used to control risk. Air lead levels ‎should reflect good hygiene practice and technical feasibility.‎ A more detailed response to the call for evidence can be found in the attachment.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

26 Jan 2022 · Discussion on industrial emissions

Battery Industry Urges EU to Avoid Duplicate Chemical Regulations

1 Jun 2021
Topic — Revision of REACH regulation governing registration and restriction of chemicals in EU.
Message — The organization requests that REACH remain the primary framework for managing hazardous substances in batteries. They oppose creating competing regulatory processes in other legislation like the Batteries Regulation, arguing this creates instability. They also urge careful consideration of the Essential Use Concept's scope.123
Why — This would prevent regulatory instability that could harm growth of the battery industry.4
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

The contribution of EUROBAT (Association of European Automotive and Industrial Battery Manufacturers) to the public consultation on the Batteries Regulation 2020/353 is included in attachment.
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Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

With this position paper, EUROBAT would like to provide its expert input on the Inception impact assessment on the End-of-Life Vehicles Directive. Timing: the proposal is severely delayed First of all, we regret that the proposal is considerably delayed compared to the own Commission legal obligation to “review the ELV Directive, by 31 December 2020, and to this end, shall submit a report to the European Parliament and the Council, accompanied, if appropriate, by a legislative proposal”. According to the Inception impact assessment, the new proposal will be published only in 2022. This is clearly a missed opportunity: the Commission published a new Batteries Regulation on 18 November, and considering the legislative overlaps between the two initiatives it would have been preferable to discuss them at the same time. Since this will not be possible, EUROBAT calls the Commission to speed up the work on the ELV Directive as much as possible. Solve legislative overlaps using the Batteries Directive as key legislative instrument on batteries The ELV Directive has caused unnecessary regulatory burden and complexity. Automotive batteries and the substances used in them are already regulated by other pieces of EU legislation: Through the Batteries Directive: the Inception impact assessment reports that “the EVs contain specific parts and components (e.g. batteries), which require specific handling when the vehicles reach the end of their life”. Exactly because this is true, batteries are already regulated through the dedicated Batteries Directive, now undergoing a major revision which will turn it into a Regulation. The document also call for new measures on recycling efficiency, recycled content, reuse, recovery of key materials for the car, but similar measures specifically targeting batteries will already be included in the Batteries Regulation. It would therefore be natural and logic to avoid legislative overlaps and take out batteries from the scope of the ELV Directive. If this will not be the case, we expect the Commission to clarify exactly how the two initiatives will interact. Since the negotiations on the Batteries Regulation are already started, we call the Commission to publicly state how they plan to solve this inconsistency. Through REACH and Occupational Health & Safety legislation (OSH): Substances used in automotive batteries and their exposure risks are regulated through REACH and Occupational Health & Safety. The majority of currently available battery chemistries contain hazardous substances in some form. However, these substances are contained in the battery article within sealed units, and are not intended to be released during normal or reasonably foreseeable conditions of use. Risks from battery materials are therefore largely limited to the workplace. Here, our industries already promote high standards of worker and environmental protection. World-leading European recyclers also work to ensure that battery materials are safely treated and recovered at their end-of-life, both for existing and new battery types. Automotive lead batteries operate in a closed loop. We therefore urge the Commission to solve this legislative overlap and use the Batteries Regulation as key legislative instrument on batteries, and REACH and OSH as key instruments on exposure risks. Additionally, we would request that Commission evaluate the existing ELV exemption criteria to ensure consistent with other waste legislation substance restriction exemptions criteria such as RoHS (Article 5(1)) where for example the availability of substitutes and the socio-economic impact of substitution, as well as life-cycle thinking on the overall impacts of the exemption apply. This approach should be applied also to ongoing exemption review.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

EUROBAT welcomes the initiative of the European Commission on Modernising the EU’s batteries legislation: in the past years, EUROBAT remarked several times the need to adapt the legislative framework on batteries to take into account the increased importance of batteries to decarbonise our economy. A coherent legislative framework is needed, considering the overlaps between the Batteries Directive, the End of Life Vehicles Directive, REACH and Occupational Safety and Health (OSH). To do so, we believe that the upcoming Batteries Regulation shall be the law of reference on product policy, removing batteries from the scope of the ELV Directive. A more detailed set of comments on the upcoming proposal on the Batteries Regulation is available here: https://www.eurobat.org/images/members/EUROBAT_position_paper_on_sectoral_meetings_on_battery_legislative_framework.pdf . During the sectoral meetings, the consultants presented some preliminary findings of the impact assessment, but they did not share the sources of the data and the assumptions presented, making it quite difficult to provide a complete feedback. The short deadline to provide comments was also an issue. For these reasons, we call the Commission to publish the final Impact Assessment as soon as possible, and to also launch a public consultation on the draft proposal before the publication of the final document, in line with the principle of better regulation.
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Meeting with Thierry Breton (Commissioner) and

25 Jun 2020 · Batteries

Meeting with Frans Timmermans (Executive Vice-President)

5 Jun 2020 · Keynote speech on batteries and the Green Deal at Eurobat Webinar

Meeting with Virginijus Sinkevičius (Commissioner) and

25 May 2020 · To exchange views on current policies developed by the European Commission affecting batteries, in particular the preparation of a new regulatory framework for batteries and the revision of the End-of-Life Vehicles Directive.

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Feb 2020 · industry policy and role of batteries in new value chains, lithium batteries as key component for electric mobility, charging infrastructure, access to global markets: trade perspectives, sustainability aspects of batteries

Meeting with Ditte Juul-Joergensen (Director-General Energy)

21 Jan 2020 · Europe's battery industry in the energy transition

Battery industry backs safety limits over REACH chemical bans

22 May 2019
Topic — The Commission is consulting on adding specific hazardous chemicals to the REACH authorization list.
Message — EUROBAT requests that lead compounds and NMP be excluded from the REACH Authorization list. They advocate for workplace safety limits instead of a full authorization requirement.123
Why — Avoiding REACH authorization would reduce administrative burdens and provide long-term business certainty for battery production.45
Impact — Environmental advocates lose the stricter phase-out requirements provided by REACH chemical authorization.6
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Response to Sustainability requirements for batteries

6 Feb 2019

EUROBAT welcomes the work of the European Commission on sustainability of batteries. Producing green batteries in Europe is fundamental to fight climate change and ensure a just transition towards a decarbonized society offering jobs and growth for all Europeans. We believe that Europe needs a coherent legislative framework to promote battery production and ensure that the batteries sold in Europe comply with high environmental and societal standards. Eco-design can be a powerful tool in this sense, but only if well designed and in connection with other policy instruments. Legislative coherence The coherence of different policy instruments shall be a founding stone for the European industrial strategy on batteries, avoiding any overlap and ensuring business certainty, fundamental to maximize private investments in this field. For instance, the key policy instrument dealing with end-of-life of batteries must remain the Battery Directive, to avoid overlaps with other tools, respecting the principle of better regulation. Scope Batteries are used in a variety of sectors, from SLI batteries to e-mobility, from energy storage to motive applications and telecommunications. Performance requirements are extremely different from one application to the other, and this is the reason why there is no one-size-fits-all among batteries, different designs and chemistries are needed to address the needs of different customers. For instance, energy density is a key feature of batteries for passenger electric vehicles, while it is not so relevant in the case of stationary storage. We therefore believe that the scope of the eco-design regulation should be limited to on-road electric vehicles. Recyclability The Circular Economy principle mandates to close the loop of resources, and recycle key materials as much as possible. We are looking forward to the upcoming proposal of the European Commission on the Battery Directive, the key legislative instrument on battery end-of-life, and we remark how the recyclability of different batteries shall be considered among the key indicators for sustainable batteries. CO2 eq content The predominant CO2 equivalent footprint of batteries takes place during production. We therefore believe that any instrument missing the CO2 eq. content of the battery is a very limited instrument. We strongly believe that the CO2 eq. content shall be taken into account in the framework of the current discussion on battery sustainability. Design criteria Durability and design for second life are often mentioned among possible sustainability requirements for second life. Recommendations on design and dismantlability could favor second life applications, but we must make sure that they do not result in undue costs for manufacturers and they do not restrict the ability to innovate: the EV battery market is still in its infancy, and it is too soon to impose design requirement. Besides, according to the draft preparatory study on eco-design, the volume of EV batteries available for second life in 2030 will outset the demand of energy storage applications by a factor of ten. For these reasons, we call the Commission to adopt a very cautious approach on durability, dismantlability and other design criteria, to avoid the creation of burdens to the industry without real benefits to the environment and to customers. Critical raw materials and socio-economic considerations Batteries manufactured with materials sourced from ethically responsible producers, respecting labour requirements and in accordance with the principle of corporate social responsibility, shall be rewarded and promoted. This involves both the environmental conditions of the mines and the social conditions of workers. Possible tools to consider these key aspects include for instance the development of rules on corporate social responsibility and the need to respect the Fundamental ILO Conventions on Labour Conditions.
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Response to Legislation on end-of-life vehicles - evaluation

30 Oct 2018

EUROBAT welcomes the EC Roadmap on the evaluation of the EU End-of-Life Vehicles Directive. Our industry believes it is particularly essential that the evaluation will look at possible inconsistencies and overlaps of the Directive with the circular economy and waste legislation, in particular the Waste Framework Directive, REACH and the Batteries Directive. It is also important to evaluate if the ELV Directive reflects the aims of this legislation such as the five step waste hierarchy, life-cycle thinking and resource efficiency. Ensuring consistency of the broader enabling and regulatory framework (Clean Energy Strategy, Mobility Packages, EU Trade Policy, etc.) in support of batteries has also been identified as objective of the European Battery Alliance and the European Commission’s Action Plan. A consistent EU regulatory framework for batteries is the pre-condition to boost the manufacturing of all battery technologies in Europe. Additionally, we would request that Commission evaluate the existing ELV exemption criteria to ensure consistent with other waste legislation substance restriction exemptions criteria such as RoHS (Article 5(1)) where for example the availability of substitutes and the socio-economic impact of substitution, as well as life-cycle thinking on the overall impacts of the exemption apply. About EUROBAT EUROBAT is the association for the European manufacturers automotive, industrial and energy storage batteries. EUROBAT has 52 members from across the continent comprising more than 90% of the battery industry in Europe. The members and staff work with all stakeholders, such as battery users, governmental organisations and media, to develop new battery solutions in areas of hybrid and electro-mobility as well as grid flexibility, renewable energy storage and demand response services. More information on our website www.eurobat.org.
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Meeting with Dominique Ristori (Director-General Energy)

4 Oct 2018 · role of batteries in the context of low carbon economy and clean energy system

Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and EUROMETAUX and RECHARGE aisbl

25 Sept 2018 · Joint meeting with Eurometaux, EUROBAT and RECHARGE to discuss the future of batteries and related chemicals management

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

20 Sept 2018 · EU battery manufacturing & REACH authorisation

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

20 Sept 2018 · EU battery manufacturing and REACH

Meeting with Piet van Nuffel (Cabinet of Commissioner Marianne Thyssen)

20 Jun 2018 · Chemical Agents Directive, protection of workers from exposure to lead

Response to Post 2020 light vehicle CO2 Regulation(s)

24 Jan 2018

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the new proposal of the European Commission to decarbonize the transport sector. Batteries will be fundamental to deliver the target of lowering the average CO2 emission by 30% until 2030 (compared to 2021) for new passenger vehicles and vans, proposed today by the European Commission: batteries of different technologies already deliver important CO2 emission savings through increased hybridisation and electrification, all the way from start-stop technology to full electric vehicles. A variety of battery technologies exists today – lead, lithium, nickel and sodium-based batteries – and they will all deliver CO2 savings in vehicles with different powertrains, which will coexist for the foreseeable future. For this reason, we think that continuous efforts on the development of all battery technologies will be a fundamental cornerstone of the transition to a decarbonized economy. Batteries will also contribute to the decarbonisation of other sectors, from energy storage and grid stability to warehouse, port logistics and telecommunication. In this sense, EUROBAT also welcomes the initiative of the European Commission to develop a coherent battery strategy to foster the production of batteries in Europe, in line with the EUROBAT proposal of a 2030 EU Battery Strategy. The global competition on the development of advanced battery technologies is particularly fierce, but the European battery industry must not lose ground compared to international competitors to enjoy the benefits in terms of competitiveness, jobs, growth and innovation. Therefore, we welcome the initiative of the European Commission to take into account the existing landscape of European battery manufacturing and evaluate the strength and weaknesses of the European battery value chain as well as the overall sustainability of batteries. Any forward-looking strategy will have to ensure policy coherence across different policy fields, also respecting the concepts of better regulation and circular economy. *** EUROBAT is the association for the European manufacturers automotive, industrial and energy storage batteries. EUROBAT has 53 members from across the continent comprising more than 90% of the automotive and industrial battery industry in Europe. The members and staff work with all stakeholders, such as battery users, governmental organisations and media, to develop new battery solutions in areas of hybrid and electro-mobility as well as grid flexibility and renewable energy storage.
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Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

13 Jul 2017 · Batteries

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

6 Jun 2017 · Discussion on launch of 2030 Battery Strategy for Europe

Meeting with Karmenu Vella (Commissioner) and

4 May 2017 · circular economy

Meeting with Miguel Arias Cañete (Commissioner)

24 Apr 2017 · 2030 Battery Strategy for Europe’.

Response to 8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles

13 Apr 2017

Lead batteries are essential for all current and future European cars.The EU must allow the continued use, with a min. 5 years before the next review of Exemption 5. The automotive/battery industries welcome the conclusions that: -As mass-market alternative battery technologies to lead starter batteries are not available Exemption 5 should be extended.This ensures the automobile industry can continue to use safe, reliable and proven mass-market batteries for SLI/ start-stop /hybrid applications. -Additional R&D, testing, and approval is needed to develop suitable mass-market alternatives to lead batteries.We requested 8 years before the next review of Exemption 5 and contend that 5 years is the absolute minimum time to gain sufficient experience in developing/testing alternative batteries. -Lead batteries are currently the only automotive battery technology operating in a closed loop (> 99% being collected/recycled at end-of-life to manufacture new batteries).Future decision-making should consider the circular economy and a wider assessment of the environmental benefits. -Drop-in solutions for alternative 12V battery technologies are currently not available for mass production vehicles without significant/expensive re-design. -Vehicle platform design has evolved around lead batteries.Vehicle/electrical architecture/design standards are closely linked to lead battery functionality, and adoption of a new technology would require significant innovation in platform design. -Socio-economic impacts must be considered when assessing the exemption for lead batteries.Europe has a long-established, globally competitive lead battery manufacturing and recycling industry, which creates a significant number of EU jobs.This is not the case for other battery technologies such as Li-ion cell production that is dominated by non-EU manufacturers. -Many current EU research projects are investigating new battery materials with enhanced properties. No decision on the use of alternative battery technologies can be made until these projects are finished. Additional points: Lead batteries are vital for: -All 12 V Starter-lighting-ignition (SLI) batteries -Virtually all start-stop/micro/mild hybrid applications (leading to significant CO2 savings) -Auxiliary power for virtually all plug-in hybrid electric and full electric vehicles. Lead batteries stand out from other battery technologies: -Safety is essential to OEMs and to their customers.Whereas Lead batteries are inherently safe, batteries such as Li-ion need carefully designed systems and testing to ensure safe operation. The high energy density of Li-ion, coupled with the use of flammable electrolytes and thin electrodes/separators make battery integrity more challenging. -The intrinsic safety of lead batteries means that they can be located in all positions in a vehicle.This is not the case for potential alternatives. -The unrivalled cold cranking properties of today’s lead batteries (to -30 or -40°C) and the robust re-chargeability mean they are irreplaceable for mass market vehicles. At low temperatures no other available battery system for volume production can meet OEM requirements. -Lead batteries can withstand a wide range of in-vehicle temperatures.In comparison, the operating temperature range for a Li-ion battery is significantly lower. ->99% of lead batteries are collected/recycled in a closed loop, and all components can be recycled. These characteristics are not currently met by alternative battery technologies. Socio-economic considerations -Lead batteries are by far the most cost-effective technology for SLI applications. The cost of using Li-ion batteries in these applications is prohibitive in most cases. ->99.99% of European cars use lead batteries. -Lead battery manufacture: 20,000 EU workers, turnover of approx €5 bn. -Lead battery recycling: 2,500 EU workers, market of approx. €2 bn. -No significant EU Li-ion cells production
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Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

30 Apr 2015 · EU Energy

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and International Lead Association

19 Jan 2015 · Discuss the impacts that a potential inclusion of four lead compounds on the REACH authorisation list would have for EU-based manufacturers and recyclers of lead-based batteries