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Bundesverband Energiespeicher Systeme e.V. / Energy Storage Systems Association

BVES

The Energy Storage Systems Association, BVES, represents the interests of energy storage companies, project developers, financial institutions, research institutes and certifiers from Germany as well as of many EU Member States.

Lobbying Activity

Response to European Critical Raw Materials Act

25 Nov 2022

The Energy Storage Systems Association, BVES, is representing energy storage companies from across the EU. It is welcoming the consultation on critical raw materials. This is an important step to develop a sufficient EU raw material strategy which will lay the basis for a net-zero economy in the EU. It will be crucial to punch the weight of the EU on the global stage and to play a relevant role as standard setter and as a market participant. Storage technologies require critical and non-critical raw materials. An electrolyser which produces green hydrogen which can be stored is made from raw materials as are batteries which are storing energy. The low diversification of EU supply sources addressed in the impact assessment is an issue which needs to be addressed. For instance, the demand for lithium will grow exponentially with the success of emobility. As prices are increasing, due to the global demand, the diversity of sources is growing too. The EU will need to ensure that it establish stable trade relationships with the countries and regions which are already and will supply in future Lithium. At the same token Member States should be encouraged to tap into their own lithium sources and allow faster permitting for refineries. However, some substances have been classified as hazardous, or are undergoing a classification process with an unknown result. This will stop or at least delay investment for lithium chloride, carbonate and hydroxide. The Risk Assessment Committee (RAC) of the European Chemicals Agency (ECHA) proposed a classification as 1A reprotoxic, despite the negative opinions of several EU Member States and trade partners such as Argentina, Australia and the US. To stay competitive the European Union will refrain from including the Lithium salts in the next Adaptation to Technical Progress (ATP) and will have to ask the RAC to re-assess its opinion. An impact assessment taking into account the impact on key policy initiatives and EU competitiveness, as well a Risk Management Option analysis (RMOA) should be carried out. The objective is, to ensure that the full impact of this action is well known and ensures that risks are minimised. To achieve a circular economy in the battery area, as the draft EU Battery Regulation points out, will make it necessary to focus not only on the batteries itself. The scrap from the production of battery materials, cells or the battery pack will also have to be considered to be effectively recycled within Europe. In the past a major share of this scrap has been exported to countries outside of the EU. This has weakened the market within the EU and withdrawn significant amounts of much needed battery metals for European producers. Especially in the critical ramp-up phase of EU recycling operations, such production scraps are an important feed material for the newly built EU recycling capacities and are crucial to reach the economics of scale needed to remain competitive. The EUs regulatory framework on waste (and batteries) should therefor clarify that production scraps as well as black mass generated as intermediate concentrate from battery shredding operations are classified as waste and not as a product that could be more easily shipped outside the EU. Moreover, in order to generate a level-playing field for state-of-the-art EU recyclers, it will also be necessary to ensure a WTO-conform agreement that the applied recycling processes have to meet minimum treatment standards and material originating from the EU cannot re-processed under lower environmental standards outside the EU.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

BVES position paper: EU Regulation proposal concerning batteries and waste batteries - COM(2020) 798/3 The EU Batteries Regulation will shape the Battery market in the forthcoming decade. The BVES welcomes the approach of the EU Commission to deliver a regulatory framework which supports key objectives of the EU Green Deal boosting the efficient use of resources by moving to a circular economy and increase the competitiveness of the industry in the EU by supporting high-performance and safety of batteries. However, to attract investments into innovative technologies, it will be necessary to have deliver a consistent and coherent approach. The BVES fully supports the statement of the DKE. . We would like to emphasise the following topics and suggest related changes: 1. Harmonised standards Article 15 is mentioning harmonised standards meanwhile Article 16 is suggesting the use of implementing acts by the EU Commission. This offers the opportunity to bypass the European Standardisation Organisation (ESO). From the point of view of the BVES, next to legal concerns, it would be crucial to have a full-impact assessment about the benefits of changing from the established regime of harmonised standards for product regulation to a new regime which would question the established way of working between the EU institutions and the ESOs. However, the BVES recommends not to bypass the ESOs. With all due respect, despite much EU commitment, we have to note that the activities up to this point show clear deficits in the understanding of battery technology, testing procedures and the market. This became obvious for experts e. g. during Ecodesign preparatory Study for Batteries, which has finally been called off. Unfortunately, we have experienced that comments and arguments which have been put forward by our experts have not been considered in an appropriate way. The input of experts (e. g. of the CENELEC SRAHG) who are dedicating their resources to the legislation process should be taken into account and considered. It would therefore be necessary to have a transparent process how minutes are written and approved. Most of the Batteries Regulation key objectives can be realised, partially even better or stricter than requested, but not necessarily in exactly the way, which is prescribed by the Commission. Some request can simply not be integrated in proven CE marking procedures or dangerous goods transportation - e. g. safety tests for batteries, which are made out of 2nd life cells in order to place them as products on the market. The Batteries regulation is correct in its finding that there is no harmonised standard for batteries yet. This is especially for correct for Li-ion batteries. The BVES appreciates the goal to initiate harmonised standards for the CE marking. But we do not share the opinion that the lack of such standards is a major hurdle for the growth and the regulation of the battery market. The safety of Li-ion batteries is well addressed since years with the EN 62133-2 (portable batteries), the EN 62619:2017 (industrial batteries) and, where necessary, harmonised standards of the Low Voltage Directive 2014/35/EU. The EN 62133-2 and the EN 62619 are even listed in Germany as non-harmonised standards, which have to be used according to the German product safety law (ProdSG).
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

BVES, the energy storage systems association, represents members from a wide range of technologies in many European countries. Energy storage provides flexibility and supports renewable energy integration in the energy system and in turn into the energy market. In this way it supports the decarbonisation of the economy, especially in buildings, industry, and transport. It is a means to safeguard security of supply. Energy storage allows the optimisation of grid development as it takes pressure away from the grid and supplements flexibility. Energy storage technologies - electrical, thermal, pumped hydro, hydrogen, etc - contribute in a systemic way to the Energy Union and its five pillars: Energy Security Fully integrated internal energy market Energy efficiency also in the context of infrastructure efficiency Decarbonisation of the Economy Increasing the competitiveness of the EU by innovation We therefore propose that all kind of storage technologies are included under the taxonomy rules. The limitation in the TEG report to electric, thermal and hydrogen is not sufficient. There is still work to be done to define energy storage technology as an asset class. It is likely that the new taxonomy rules will have an impact on how companies - which have a role in the storage value chain - will be rated. However, it will be crucial not to exclude storage technologies. The financial sector is investing more and more in storage technologies. The financial market regulations as well as environmental regulations and the taxonomy need to be comprehensive to ensure a coherent reporting. The taxonomy may create a non-financial reporting standard which will impact the way in which banks, insurances, and non-financial companies are rated and how they are operating. A coherent approach which encourages the markets will be welcomed. Market principles should be applied. The EIB has a very important role to play to encourage innovative and sustainable investments in sectors where market failure occurs. However, financial instruments which are dependent on the state, such as the Carbon Contract for Difference (CCfD), may cause the risk of interfering into the ETS by taking parts of the industry out of the ETS. It also should be considered that the CCfD might be reducing the effectiveness of the price signal as a short and long term operational and investment decisions driver. We welcome the fact that the draft of the delegated act outlines the importance of hydrogen storage facilities for a successful implementation of the EU hydrogen strategy. However, the natural gas transport infrastructure should be taken into account as it will play a key role in transporting hydrogen. We believe that the legislation should be postponed until all Delegated Acts for all environmental targets are known. We also want to emphasise our view that it will not be possible to assess effectively in just a few days the various responses to the consultation. BVES is very grateful for this opportunity to put forward our views on this very important subject.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The EU renewable energy rules (Directive 2018/2001/EU) puts the active customers at the centre. The Directive is suggesting to introduce market-based systems to make the markets fit for increasing shares of renewable energy. It is asking the Member States to increase the market integration of renewable electricity while taking into account the different capabilities of small and large producers to respond to market signals. The empowerment of the customer is the key element of the Directive. It suggests that the development of decentralised renewable energy technologies and storage under non-discriminatory conditions, without hampering the financing of infrastructure investments should provide the benchmarks for a decentralised energy system within the EU. The objectives of the energy policies shall be the affordability of energy prices. Low energy prices will increase the competitiveness of the industry EU and fight energy poverty. The review of the Directive should ensure the integration of renewable energy into the energy market. It should take into account the role of the flexibility storage technologies is providing a cost-efficient energy transition and to high levels of security of supply and system stability. It should outline a clear strategy how short-term and long-term storage, small-scale, large-scale and industrial scale could and should interplay to offer the best solutions for the customers. Storage allows the decarbonisation of the energy sector, the sector with the highest GHG-emissions, by making it possible to store energy for seconds or months. Storage allows the renewable-based electrification of road transport, heating, and cooling in buildings and of the industry. It would allow to build a cost-efficient charging infrastructure and provide hydrogen for many purposes which rely nowadays on fossil fuels. The review of the Directive should ensure the integration of renewable energy into the energy market. It should take into account the role of the flexibility storage technologies are providing to a cost-efficient energy transition and high levels of security of supply and system stability. It should outline a clear strategy how short-term and long-term storage, small-scale, large-scale and industrial scale could and should interplay to offer the best solutions for the customers. Storage allows the decarbonisation of the energy sector, the sector with the highest GHG-emissions, by making it possible to store energy for seconds or months. Storage allows the renewable-based electrification of road transport, heating, and cooling in buildings and of the industry. It would allow to build a cost-efficient charging infrastructure and provide hydrogen for many purposes which rely nowadays on fossil fuels. It will be necessary to ensure that the principle of unbundling is applied. Unbundling ensures that the necessary investment from the private sector will be activated. Companies deriving from the regulated are not in the position to offer the most sustainable, innovative and cost-efficient solutions. The investments and the insurance needed to allow the energy sector to transform could not be sustained solely by the public banking sector in a sufficient way. The proposed options 1 to 5 focus on abstract objectives and respectively very detailed measures. The focus of the review shall rather emphasise the potential of storage to achieve the EGD objectives. It will therefore be necessary to review the NECPs of the Member States if they are proposing to implement the REDII legislation or if they are ignoring it. The implementation of the REDII legislation should not be way, inter alia, to choose amongst various legislative options. As it is known: Most Member States require operators of storage facilities, especially including the active consumers, to pay network charges and/or energy taxes and/or other levies twice. It is also very common to have a bureaucratic system of insufficient exemption rules which
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Response to A EU hydrogen strategy

8 Jun 2020

The German Association Energy Storage Systems represents the interests of more than 200 members from Germany as well as from other EU Member States. Its members are specialised in all kind of storage technology from battery, heat to H2 etc. We welcome the roadmap as a major step forward towards the success of the EU Green Deal by decarbonising our society and economy. We support the priority for green hydrogen as it facilitates pro-market business models in a decentralised energy world. We support the integrated systemic approach of the road map: “Renewable hydrogen supports the integration of renewable electricity generation as it decouples the energy production and usage in location and time and can balance electricity demand and supply. This is amongst other uses also important for electricity grid management, and as well for isolated or stand-alone regions of the EU, or for specific and local uses concentrated in a restricted area or city”. The roadmap mentions hydrogen as a means which “also provide long-term, large-scale storage, and flexibility to the energy system”. Hydrogen is an energy carrier which can be stored. And it is the storage infrastructure in which this hydrogen is stored. Therefore, it is very important to have a clear understanding about the storage infrastructure, its capacities and how it is regulated. However, H2 allows to store energy in a very flexible way. Therefore, it is very important to have a detailed knowledge about the capacity needs of the storage infrastructure its capacities and the way how it is regulated. It is not sufficient to limit the focus on transport infrastructure and the investment needed for this specific feature. Transport and storage infrastructure build the backbone of a reliable hydrogen-based energy system which addresses the key features of the European energy system, flexibility, and the security of supply. Green Hydrogen will not only contribute to the flexibility of the European energy system but will also ensure the security of supply and will therefore benefit consumers and industry with a cost-efficient level of reliability provided the following regulatory issues are addressed: As prerequisite for a sector integration and a hydrogen strategy, a large scale of additional renewable power installations is needed. The non-power sectors combine a huge demand for energy. To decarbonise those sectors with hydrogen, new capacities of renewable power production needs to be installed in the next years, in addition to the capacities needed to decarbonise the power-sector itself. Recommended action: Support the implement the renewable energy strategies in the Member States In many Member States, including Germany, the electrolyser is defined as ultimate user. Fees, levies, and taxes have to be paid for the electricity used and when H2 is used the state-imposed share of the price is due to be paid again. The multiple or sometimes double charging of a kilowatt with network tariffs and net metering is still a major barrier for storage as well as to the electrolyser. In addition, there are certain bureaucratic exemptions which are not sufficient to attract private investment on a larger scale. Recommended action: Re-draft the Market Design Directive and REDII to provide a clear definition of the role of the electrolyser as well as for storage of hydrogen in the energy system. Revise the energy taxation directive to reduce the cost-burden imposed on green hydrogen by the Member States. Please find attached our detailed paper.
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