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International Lead Association

ILA

The International Lead Association represents the global lead mining, smelting, refining, and recycling industry.

Lobbying Activity

International Lead Association urges harmonised EU recycling rules

17 Sept 2025
Topic — The EU is consulting on legislation to promote sustainable production and circular business models.
Message — The association demands simplified cross-border waste transport and uniform standards for recycled metals. They also seek streamlined permitting and dedicated innovation funding for recycling plants.123
Why — Reducing administrative burdens would lower operational costs and protect their domestic market share.45
Impact — Non-EU waste processors lose access to European materials due to proposed export restrictions.6
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Meeting with Letizia Moratti (Member of the European Parliament)

7 May 2025 · environmental policy

Meeting with Andrea Wechsler (Member of the European Parliament) and Repsol, S.A.

7 May 2025 · EU Energy and industry policy

Meeting with Giorgio Gori (Member of the European Parliament)

6 May 2025 · Energy storage, Battery production and recycling

Meeting with Niels Flemming Hansen (Member of the European Parliament)

6 May 2025 · Save the electricity grid

Meeting with Jüri Ratas (Member of the European Parliament)

6 May 2025 · Clean Industrial Deal and the EU Grids Package

Meeting with Yannis Maniatis (Member of the European Parliament)

26 Mar 2025 · Introductory Meeting

Meeting with Filip Turek (Member of the European Parliament, Shadow rapporteur)

26 Mar 2025 · Circularity requirements in vehicle design and end-of-life vehicles

Meeting with Barbara Bonte (Member of the European Parliament)

30 Jan 2025 · Recycling lead batteries

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

22 Jan 2025 · Battery technology

Meeting with Borja Giménez Larraz (Member of the European Parliament)

21 Jan 2025 · Priorities for the new mandate

Meeting with Pascal Arimont (Member of the European Parliament)

21 Jan 2025 · Developing batteries in Europe

Meeting with Ondřej Krutílek (Member of the European Parliament)

19 Dec 2024 · Battery regulation and reach

Lead association warns of battery recycling calculation loopholes

18 Oct 2024
Topic — Standardizing the methodology for calculating battery recycling efficiency and recovering critical materials.
Message — The association demands mandatory reporting of all battery components to ensure accurate efficiency rates. They also seek stricter verification for non-EU recyclers to close regulatory loopholes. Finally, they suggest simplifying documentation to avoid unnecessary administrative burdens.1234
Why — Stricter rules protect high-standard European recyclers from cheaper, less efficient foreign competition.5
Impact — Non-EU recyclers with lower standards lose their competitive price advantage over European firms.6
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Lead industry urges removing battery restrictions from ELV law

22 Nov 2023
Topic — EU proposal to improve vehicle design circularity and manage end-of-life cars.
Message — The association requests that restrictions on battery substances be removed from the ELV Regulation. They want the 2025 lead exemption review moved into the EU Batteries Regulation.12
Why — This would prevent regulatory overlap and eliminate uncertainty for battery producers.34
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Meeting with Nikolaj Villumsen (Member of the European Parliament, Rapporteur)

30 May 2023 · CAD-CMRD Directive

Meeting with Ilan De Basso (Member of the European Parliament, Shadow rapporteur)

3 May 2023 · CMRD & CAD

Lead Association questions lack of transparency in pollutant reclassification

23 Nov 2022
Topic — This consultation reviews lists of chemical pollutants affecting European surface and groundwaters.
Message — The association expresses concerns about the lack of transparency in promoting lead to a hazardous substance. They question if lead meets the scientific criteria for concern regarding the aquatic environment.123
Why — Avoiding the hazardous designation prevents lead producers from facing more stringent environmental quality standards.4
Impact — Environmental groups lose the stricter monitoring and protection levels associated with hazardous substance status.5
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Lead industry association demands longer exemptions for vehicle batteries

27 Jun 2022
Topic — Review of heavy metal exemptions for batteries in end-of-life vehicles.
Message — 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.12
Why — Extended exemptions protect the industry's dominance in the low-voltage battery market.34
Impact — Special purpose vehicle manufacturers lose market access without a sufficient transition period.56
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Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

16 Mar 2022

The International Lead Association (ILA) is the global trade association for the lead industry representing member companies involved in lead mining, smelting and recycling. ILA acts as the secretariat for the Lead REACH Consortium that was established in 2008 to help companies meet their REACH obligations for lead metal, lead chloride, and ten lead compounds covered by the Voluntary Risk Assessment for Lead (VRAL). We agree with the conclusion of both RAC and the ACSH that biological monitoring, in the form of regular blood lead testing, is the most effective index for managing the health of workers exposed to lead. Experience of companies over decades has demonstrated that the body burden of lead in individuals following occupational exposure is not well correlated to workplace air concentrations. Given the significant uncertainties in estimating the air lead levels required to achieve target blood lead limits we believe that any future BOELV should be established to reflect good hygiene practice rather than attempting to use it as a quantitative measure of exposure linked to a health metric. Evidence gathered to support REACH registrations and following interviews with our own member companies highlights that adopting an EU BOELV lower than 50ug/m³ (8hr TWA) will likely be beyond technical and socio-economic capabilities of many EU companies and will likely result in a significant number of discontinuations and site closures. Medical surveillance of lead exposed employees is a critical element in an effective risk management programme. In lead producing industries, typically all employees are enrolled in a medical surveillance programme upon start of employment. We therefore believe that the current mandatory trigger for medical surveillance requirements in the CAD must be lowered and that 10µg Pb/dL blood and/or when exposure to a concentration of lead in air is greater than 25ug/m³, calculated as an 8hr time-weighted average over 40 hours per week could be considered. There is wide range in performance in managing employee lead exposures in companies producing and using lead in the EU. One reason for this is that national limits currently in force in Member States range from 15 to 70µg Pb/dL blood. There are therefore many employees across the EU that will have blood lead levels significantly higher than the 15 µg Pb/dL blood that has been advised by the European Chemicals Agency. We believe that a biological limit value of 15µg Pb/dL should eventually be achievable in many companies involved in battery manufacturing and recycling but that this would represent a significant technical and socio-economic challenges for companies processing lead containing ores . Any proposed future EU binding biological limit value must consider not only health, technical and socio-economic feasibility but also the toxicokinetic’s of lead. In that regard we believe that a long transition period will be required for any future binding limit value lower than 30µg Pb/dL to allow companies to make changes to work practices and importantly for the blood lead level of longer service employees to fall given the long half-life of lead in the body. Other response measures, such as medical removal from exposure, may be appropriate for individual employees who present with higher blood lead values. While medical removal was not discussed by ACSH, and therefore ILA has not taken a position as to an appropriate binding medical removal value, we believe a value of 30ug/dL could be considered. ILA’s position paper on the current plans to revise the EU Binding Workplace Limits for lead is attached.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

The International Lead Association representing Europe’s lead battery recyclers, primary lead producers and mining companies welcomes the proposal for a new comprehensive European battery regulation that aims to improve the quality, sustainability, transparency, and social responsibility of the battery value chain. The existing circular economy model for lead batteries, that enables a very high collection rate and recycling efficiency to be achieved through a comprehensive network of high performing recyclers operating in many Member States, is the EU gold standard. Our Members have some concerns that the current proposal may not have adequately considered the role of independent lead battery collection and recycling operators that deliver these services. We would welcome further discussions with the Commission to ensure that appropriate safeguards are in place to ensure that this highly efficient process is not inadvertently disrupted by any new legislative provisions. We support the legal basis for the Regulation based Article 114 of the Treaty on the Functioning of the European Union (TFEU), since it is important to harmonise many measures across Member States. However, we would like Commission to clarify how they plan to ensure that appropriate enforcement will take place to make the Regulation equally effective for batteries manufactured and recycled in or outside of the EU. We support the Commission proposal to include specific recycling efficiency and material recovery targets and welcome the adoption for the first time of requirements for lithium-ion batteries given the importance this technology will play in carbon reduction goals and the predicted increases in market volumes. However, we believe it is premature to establish recycling efficiencies and recovery targets for materials before rules regarding the calculation methods has been published as the ability of companies to achieve mandatory levels will be very dependent upon the eventual methodology adopted. As a general comment we are concerned that many important aspects that will impact the ability of the sector to comply with the Regulation have yet to be defined and are rather left to future implementing acts. We believe to provide greater business certainty, the use of implementing acts should be minimised and that greater detail should be included in the Regulatory proposal itself. Detailed feedback on specific elements of the proposal is detailed in the document attached to this submission.
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Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton)

9 Sept 2020 · Upcoming Batteries Regulation and the position of the lead acid battery sector

Response to Commission Regulation amending Annex XIV to REACH

22 May 2019

The International Lead Association (ILA) is a membership body that supports companies involved in the mining, smelting, refining and recycling of lead. The ILA represents the producers of about 3 three million tonnes of lead. ILA’s work has a broad focus, covering all aspects of the industry’s safe production, use and recycling of lead. In its capacity as Secretariat to the Lead REACH Consortium, ILA acts on behalf of the Lead Registrants for several lead substances including lead monoxide, lead tetroxide, pentalead tetraoxide sulphate and tetralead trioxide sulphate. In the EU, tetralead trioxide sulphate, pentalead tetraoxide sulphate, orange lead (lead tetroxide), and lead monoxide (lead oxide) are used almost exclusively in the manufacturing of lead based batteries. They are not present in the batteries ready for use and placed on the market so exposure is restricted to industrial uses that are already covered by lead specific provisions in Council Directive 98/24/EC, Directive 92/85/EEC and Directive 2010/75/EU of the European Parliament and of the Council and its implementing measures establishing Best Available Techniques (BAT) conclusions. We support the Commission’s observation that through implementation of Directive 2010/75/EU and its predecessors, emissions of lead and its compounds to the environment have decreased and continue to decrease as shown by the European Pollutant Release and Transfer Register (E-PRTR) reporting. We therefore agree with the Commission proposal to focus on a review of the current Union binding occupational limit value and binding biological limit value for lead compounds under Directive 98/24/EC and to postpone a decision on the inclusion of those substances in Annex XIV to Regulation (EC) No 1907/2006. We have long stated that these binding limit values no longer represent the technical measures now adopted by Industry to control lead exposures in the workplace nor the latest science on health effects of exposure to inorganic lead compounds. A revision of the current EU workplace binding limit values is a more proportionate risk management option at this stage as it will benefit a far higher number of EU workers than inclusion of the four lead compounds in Annex XIV to Regulation (EC) No 1907/2006. A review of the workplace binding limit values will cover all potential workplace exposures to the listed lead compounds, and additionally other lead compounds and lead metal. Moreover as a significant number of workers in the EU are not actually using lead or lead compounds but may nevertheless be exposed during their employment (e.g. demolition industry, paint removal, scrap industries, plumbing etc), a review of the existing workplace binding limit values has additional health benefits that go beyond those afforded by REACH Authorisation.
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Lead industry association urges consistent EU rules for battery recycling

30 Oct 2018
Topic — Evaluation of the Directive regarding environmental impacts of end-of-life vehicles.
Message — The association seeks to align vehicle exemption criteria with other waste legislation. They advocate for considering socio-economic impacts and the benefits of closed-loop recycling.12
Why — Consistent regulations would help the industry maintain its competitiveness and protect local manufacturing.3
Impact — Foreign producers of battery minerals may lose market share to European lead recycling.4
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International Lead Association urges five-year vehicle battery exemption extension

13 Apr 2017
Topic — EU consultation on lead substance restrictions for end-of-life vehicle batteries.
Message — The industry requests a minimum five-year extension for lead battery exemptions. They argue mass-market alternatives are currently unavailable and require significant research and testing.12
Why — The exemption avoids expensive vehicle redesigns while protecting thousands of European manufacturing jobs.34
Impact — Non-European lithium-ion manufacturers lose the opportunity to enter the mass-market starter battery sector.5
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Association of European Automotive and Industrial Battery Manufacturers

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