Exide Technologies GmbH
Exide
Exide Technologies is a global provider of stored electrical-energy solutions for automotive and industrial application.
ID: 295082640195-45
Lobbying Activity
Response to Heavy metals in end-of-life vehicles (updated list of exemptions)
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 lead in batteries.
During the consultation for the exemption review, evidence was provide that Lead based batteries remain the only technology that can meet all OEM technical requirements for 12V SLI and auxiliary functions in M1 and N1 vehicles, including functional safety, high temperature durability and cold cranking.
Exide wishes to draw the attention on two critical elements of the draft Delegated Directive:
The next exemption review must take place not earlier than five years after the conclusion of the current assessment of technical and scientific progress, and after the publication of the ongoing review of the ELV Directive. This is of paramount importance to provide industry with the necessary regulatory visibility to progress on the recommendations from the current assessment.
The recommendation to restrict the use of lead batteries above 12V is misplaced as no evidence was requested during the consultation on technical performance of batteries with this voltage nor is any presented in the consultant’s report to the Commission. It would be inappropriate for the commission to conclude that lead-free alternatives are available for applications utilising 24V or 48V batteries without undertaking the due process of gathering sufficient evidence to demonstrate that lead use is avoidable in these applications.
The details of our feedback can be found in the attached document.
Read full responseResponse to Protection of workers health from risks related to exposure to lead and di-isocyanates
18 Mar 2022
Exide Technologies is a producer of lead and lithium based batteries, as well as a recycler of lead based batteries. As such, Exide is an active member to Industry associations that deal with our raw materials (e.g. International Lead Association) and or products and services (EUROBAT).
Exide Technologies is committed to ensuring the health and wellbeing of our employees. This is illustrated by the fact Exide has a long established voluntary lead exposure reduction program that goes beyond current regulation and have delivered impressive results in reducing employee lead exposures over time.
By the end of 2022, 3.400 male and 150 female employees of Exide had been under medical surveillance due to occupational exposure to lead metal and lead compounds.
Based upon the experience we have made with lead exposure reduction programs since the early 2000s, Exide recommends a pragmatic stepwise approach that clearly focuses on a biological limit value for blood lead rather than an occupational exposure limit for lead in air. Please find our detailed comments attached.
For further information, please contact:
Karsten Kurz, Director Environmental Affairs Europe
Karsten.Kurz@exidegroup.com
Read full response