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European Portable Battery Association

EPBA

The EPBA is the leading organisation representing quality manufacturers of portable power solutions, working with stakeholders to safeguard and enhance our positive contribution to the EU economy, the environment, and the communities in which we operate.​

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

Please find our position paper enclosed.
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Meeting with Boriša Falatar (Cabinet of Commissioner Hadja Lahbib)

16 Oct 2025 · EU Preparedness Union Strategy

Response to Waste batteries - Format to be used by Member States reporting on their collection and treatment

8 Aug 2025

EPBA - Consumer Batteries Europe welcomes the opportunity to provide comments on the draft regulation. Our comments are as follows: Annex 1 of the draft regulation Table 1 shows the reporting format for Portable Batteries (which also include portable batteries of general use). The 3rd line is referencing Nickel-Cadmium which is a chemistry which has already been banned for use in portable batteries (with a few exemptions) under Battery Directive 2006/66/EC from September 2006. Under the Batteries regulation, all exemptions for portable batteries are removed, so effectively it does not make sense to include this chemistry in the reporting format. On the other hand, Nickel Metal Hydride is not mentioned anywhere even though this is the main rechargeable chemistry for consumer market, interchangeable with primary alkaline cells. We also do not understand the logic for making the reporting of non-rechargeable portable batteries voluntary. We know that the vast majority of portable (consumer) batteries put-on-market is still non-rechargeable, and this group also contains critical raw materials like Manganese compounds and Lithium. In Table 2 (LMT Batteries), the Nickel Cadmium reference is replaced by Nickel-based. This would in general make more sense to use consistently in the reporting formats, except in Table 4 (Industrial Batteries). In the industry, Nickel Cadmium chemistry is still used on larger scale for particular markets like aviation, industrial standby applications, trains, offshore platforms, and powering telecom masts.
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Response to Omnibus Regulation Aligning product legislation with the digital age

23 Jul 2025

In response to the Commission proposal for a Regulation regarding Digitalisation and the Alignment of Common Specifications, we consider it crucial that the EU product legislation is aligned with the digital age. We support the proposed changes for the conformity assessment procedures of batteries which would slightly reduce the administrative burden of the industry. Most importantly, we advocate also for the use of QR codes or URLs as a primary source of information about batteries, fully in line with the new rules on labelling of ingredients and nutritional values on wine. Download the full position paper below.
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Response to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Regulation

23 Jul 2025

In response to the Commission proposal for a Regulation on Simplification Measures for Small Mid-Cap Enterprises2 , we seek further improvements to the Due Diligence rules for batteries in order to create fair level playing field for our members, and other battery manufacturers. As expressed in our earlier position paper dated 22 May3 , we fully support a consistent set of rules to foster environmental and human rights standards for critical raw minerals. Our supply chains are no different to those for steel products; animal feed; brick colorants; fertilisers; brass and bronze production, chemically resistant materials; electrical conductors; etc. nor should be the applicable Due Diligence requirements. We take note of the current public debate about the Omnibus simplification package, notably the position of the Council on due diligence requirements4 . To close the gap with the EUBR, we are proposing that Chapter VII of EUBR shall not apply to economic operators with less than 5,000 employees and EUR 1.5 billion net turnover. The scope of Chapter VII of EUBR shall be strictly limited to addressing risks in the battery supply chain such as the material operations of smelters/refiners, and of sourcing mines for raw minerals representing at least 10% of the battery producers total raw materials value. The report of economic operators on their individual battery due diligence policies, as referred to in Article 48(1) EUBR, shall be reviewed and made publicly available every five years. Download the full position paper below.
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Response to Proposal amending the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations

23 Jul 2025

We welcome the Commissions decision to delay the implementation of Chapter VII of the Batteries Regulation by two years. This pause is essential to finalise key elements such as implementation guidelines, the designation of notifying authorities by member states, and alignment with the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). At the same time, we underline the need for proportionate and workable due diligence requirements. Our position includes concrete proposals to better tailor the scope and frequency of reporting obligations and to ensure a level playing field across sectors handling critical raw materials. In parallel, we support efforts to modernise EU product legislation in line with the digital transition. This includes the use of QR codes or URLs for battery information, in line with similar initiatives in other sectors such as food and beverage labelling.
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné), Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné)

5 May 2025 · Batteries Regulation Due Diligence and Omnibus I proposal

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

1 Apr 2025 · Omnibus

Response to European Critical Raw Materials Act

30 Jun 2023

Our EPBA position is enclosed.
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Meeting with Silvia Modig (Member of the European Parliament, Shadow rapporteur)

25 Oct 2021 · Batteries and waste batteries

Response to Modernising the EU’s batteries legislation

1 Mar 2021

The detailed feedback of EPBA (European Portable Battery Association) on the Commission's proposal is available in the enclosed document.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

20 Oct 2020 · Restriction of primary batteries, Use of recycled materials, Collection targets portable batteries

Response to Modernising the EU’s batteries legislation

8 Jul 2020

EPBA is the trade association representing manufacturers and importers of consumer batteries in Europe. Our member companies are committed to innovation and are constantly striving to offer enhanced quality and performing batteries that contribute to the transition to a more sustainable and circular economy. EPBA welcomes the opportunity to contribute to the inception impact assessment of the most relevant piece of legislation affecting our sector. We have been actively involved in the process from the start and remain open for a constructive dialogue, sharing our industry knowledge and advising on the feasibility of the different policy options under discussion. It is with great concern that we see the phase out of primary batteries listed as one of the key objectives of the new legislation. The fact is that such a drastic measure will not bring any environmental social or economic benefits. As a result we oppose to that and offer to discuss minimum quality standards which will in turn result in safer and higher quality portable batteries. In the enclosed file you will find other points we deem crucial both for our sector as well as for effectively delivering on the Green Deal and Circular Economy Action Plan.
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Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

28 May 2020 · Revision Batteries Directive

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

The European Portable Battery Association (EPBA) is the authoritative voice of the portable power industry. The association supports the common interests of its members regarding portable batteries and battery chargers with European institutions and other leading international bodies to provide consumers with complete power solutions which are sustainable across their life-cycle. EPBA welcomes this consultation and wishes to bring the attention of the European Commission to a specific point about the classification proposal of cobalt and impact on the sector we represent. Cobalt is added intentionally to steel battery casings of portable Alkaline batteries to prevent the formation of non-conductive oxide layers on the inside can surface after storage reducing the contact resistance between the cathode and the can. Therefore the effect of the Co plating is biggest on high current discharge tests, where the internal resistance is crucial, like the digital still camera test (DSC). There is little difference between Ni/Co plated and only Ni plated cans, if a fresh battery is tested. The difference is significant for batteries tested after storage. Depending on the test, the difference can range from 6% - 13%. As such the use of added Cobalt to the battery casing of portable Alkaline Batteries has a positive effect on the performance of these batteries. Without added Cobalt, the life-span of Alkaline batteries will be reduced and would result in more waste creation which goes against the general principles of circular economy. EPBA members are striving to implement circular economy principles to the design and production of their products as long as it is technically applicable and economically viable. We therefore wish to underline the importance of cobalt to the battery casing of portable Alkaline Batteries
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