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RECHARGE

RECHARGE is the European industry association for advanced rechargeable and lithium batteries, representing the full value chain from raw materials to recycling.

Lobbying Activity

Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

19 Dec 2025 · Questions on the Automotive Package

Meeting with Mohammed Chahim (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

10 Dec 2025 · Informal stakeholder roundtable meeting on the automotive package

Meeting with Tiemo Wölken (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

10 Dec 2025 · S&D Stakeholder Exchange on the automotive package

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra)

27 Nov 2025 · Battery production and automotive package

Meeting with Alexandre Paquot (Director Climate Action) and

20 Nov 2025 · RECHARGE roadmap

Meeting with Stéphane Séjourné (Executive Vice-President) and

15 Sept 2025 · - Compétitivité des entreprises - Relation Japon/UE avec les USA - Decarbonation - Batterie, chaine de valeur - Voiture electrique

RECHARGE Urges Inclusion of Battery Sector in ETS Aid List

5 Sept 2025
Topic — Updates to state aid rules compensating energy-intensive industries for rising carbon-related electricity costs.
Message — RECHARGE requests that the battery sector becomes eligible for state aid to compensate for electricity costs. They argue that updated data justifies including battery manufacturing as a sector at high risk.12
Why — Compensating electricity costs would help European battery manufacturers compete against lower-priced imports from Asian countries.34
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RECHARGE supports postponing battery due diligence rules for alignment

19 Jul 2025
Topic — A proposal to postpone battery due diligence obligations and align reporting requirements.
Message — The associations support postponing obligations and recommend aligning rules with other EU sustainability laws. They suggest allowing group-level due diligence and consolidating reports to reduce duplication.123
Why — Aligning regulations would reduce administrative costs and provide companies with greater legal certainty.45
Impact — Environmental groups may lose timely oversight of battery supply chain impacts due to delays.6
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RECHARGE seeks dedicated EU funding to scale battery production

8 Jul 2025
Topic — A review of the Innovation Fund's effectiveness in supporting climate-related industrial technologies.
Message — RECHARGE requests a tailored Innovation Fund with output-based production support for the battery ramp-up phase. They urge the Commission to earmark funding and implement local content requirements to boost demand.12
Why — This would lower marginal production costs and provide bankable support during volatile early operations.34
Impact — Global battery exporters would lose market access because local content requirements favor European production.5
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

8 Jul 2025 · Batteries

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

20 Jun 2025 · Exchange of view about the development of the Best Available Techniques Reference Document (BREF) for batteries manufacturing

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and logos public affairs

12 Jun 2025 · Regulations on batteries

Meeting with Alexandre Paquot (Director Climate Action)

22 May 2025 · Battery value chain

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Verkor and Automotive cells company

3 Apr 2025 · Battery production and value-chain

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

26 Feb 2025 · Automotive Action Plan

Meeting with Stéphane Séjourné (Executive Vice-President) and

19 Feb 2025 · Dialogue on the future of the automotive sector – Battery Session

Meeting with Bruno Tobback (Member of the European Parliament)

7 Feb 2025 · ZEV, end of life vehicles, recharge infrastructure

Meeting with Laura Ballarín Cereza (Member of the European Parliament)

6 Feb 2025 · Batteries, Industrial Policy

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

6 Feb 2025 · Exchange of views on automotive sector

RECHARGE demands single market for end-of-life battery waste

31 Jan 2025
Topic — The European Commission is consulting on strategies to remove single market barriers.
Message — RECHARGE wants a true Single Market by harmonizing battery waste shipping rules. They request automated authorization and fast-track procedures for transporting spent batteries. The association also demands uniform implementation of producer responsibility rules across Europe.123
Why — Harmonized rules would lower administrative costs and accelerate recycling of critical materials.4
Impact — Global competitors lose access to battery materials currently leaking out of Europe.5
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Meeting with Mohammed Chahim (Member of the European Parliament)

22 Jan 2025 · Clean Industrial Deal/Circular Economy

Meeting with Brando Benifei (Member of the European Parliament)

21 Jan 2025 · decarbonising energy, clean mobility, digital transformation

Meeting with Virginijus Sinkevičius (Member of the European Parliament)

21 Jan 2025 · EVs, energy

Meeting with Jens Gieseke (Member of the European Parliament) and Daimler Truck AG

21 Jan 2025 · Austausch zu EU Politik

Meeting with Emma Wiesner (Member of the European Parliament)

21 Jan 2025 · Clean Industrial Deal, cirkulär ekonomi, kritiska råmaterial

RECHARGE urges clearer waste definitions to support European battery recycling

8 Nov 2024
Topic — The Commission is revising the List of Waste to reflect new battery technologies.
Message — The association recommends adding a specific definition for black mass to the waste list. They propose fast-track shipping procedures for hazardous waste sent to approved recycling centers.12
Why — A stable legal framework will help companies secure long-term investments in battery recycling.3
Impact — International exporters lose profits as stricter codes prevent valuable waste from leaving Europe.4
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RECHARGE Urges Simpler Battery Recycling Reporting Rules

18 Oct 2024
Topic — New methodology for calculating and verifying battery recycling efficiency and material recovery rates.
Message — The association seeks simpler reporting templates and updated formulas to reflect multi-year processes. They also request improved information sharing between different operators in the recycling chain.123
Why — These changes would reduce administrative burdens and prevent the reporting of inaccurate performance data.45
Impact — Regulators lose detailed geographic data about where specific waste batteries were originally collected.6
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RECHARGE urges realistic carbon footprint methodology for batteries

28 May 2024
Topic — Commission rules establishing the methodology for calculating electric vehicle battery carbon footprints.
Message — RECHARGE requests distinct categories for hybrid batteries and more transparent reporting standards. They argue three-decimal resolution is misleading because numerous assumptions are made.12
Why — Adjusting these rules would prevent unfair technical disadvantages for hybrid battery producers in Europe.3
Impact — Environmentally conscious consumers lose out if firms use secondary data to engage in greenwashing.4
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Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

To achieve EU Green Deal objectives, the European Commission has identified batteries as a strategic value chain, enabling sustainable development, green mobility, clean energy, and climate neutrality. Batteries are a key enabling technology for the green transition away from fossil fuels. Batteries are essential to the functioning of society: They power a wide range of applications such as smartphones, tablets, power tools, hearing aids, defibrillators, safety lighting in public buildings, and provide many services to industry such as back-up power for mission critical industrial assets including nuclear power plants and internet data centres. Battery storage helps renewable generators reliably integrate with existing grids by storing the excess generation and by smoothing the energy distribution. The battery industry is also responsible for generating significant economic growth. The co-legislators have adopted the Regulation (EU) 2023/1542 concerning batteries and waste batteries which entered into force on 17 August 2023. The Regulation sets out rules on sustainability, performance, safety and other aspects covering the entire life cycle of batteries. A key issue slowing down the development of a sustainable and competitive EU battery value chain is incoherence between EU climate objectives and EU chemicals policy. RECHARGE underlines the importance for coherence between these policies to allow predictability for investment. The batteries value chains highest barrier is REACH-related chemical rules incoherent with EU battery ambition which translates into measures attached to permitting or which bring uncertainty to the economic actors willing to invest into new projects or expanding existing ones. The industry observes a lack of consultation related to product management and increasingly often the rules set by the European Chemicals Agency (ECHA) are not feasible for the industry. The principle of prevention of harm is the fundamental principle of the REACH Regulation, based on a risk control approach. In addition, the requirement to control the chemicals risk is complemented by multiple other EU regulations such as the Industrial Emissions Directive, the Waste Framework Directive, and the Health and Safety at Work regulations. In the new Batteries Regulation, the Extended Producer Responsibility (EPR) has been clarified particularly concerning the obligation to ensure that the batteries will be recycled, and that the key material(s) will be recovered. Efforts should be made to continue ensuring that the risk control of hazardous chemicals is correctly implemented for all usages liable to harm society, rather than aiming at removing or limiting these substances: Please read more to this in the attached paper. For example, PFAS in batteries are essential: Their unique properties are critical and irreplaceable to the functioning of batteries - they are repellent (to water, oil and dirt); durable (under extreme conditions) and provide electrical and thermal insulation. As a result of their chemical resistance and tolerance to a high range of working temperatures, PFAS are present in key components for all high performance and lithium battery technologies. RECHARGE provided an in-depth analysis to the ECHA PFAS restriction consultation evaluating whether there are any non PFAS alternatives. Please download the dossier here: https://rechargebatteries.org/wp-content/uploads/2023/09/FINAL-SECOND-SUBMISSION-.pdf
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Response to European Critical Raw Materials Act

30 Jun 2023

In the context of the REPowerEU plan and the need for Europe to increase resilience in its energy transition value chains, RECHARGE the leading voice of the European advanced rechargeable and lithium batteries value chain in Europe welcomes the Critical Raw Materials Act (CRMA). With the CRMA the European Commission has rightfully identified actions to tackle the challenge of supply of batteries materials and to further stimulate the domestic production of battery raw materials. The CRMA together with the Net-Zero Industry Act (NZIA) has the potential to become a real game changer for competitiveness of the European battery value chain. RECHARGE expects the Act to urgently push forward its European mining, refining and recycling projects to establish a minimum level of strategic autonomy, while establishing key partnerships with resource-rich countries which comply with EUs ESG standards. Batteries play a key role as enablers of a green energy system and, by extension, of energy security. To ensure the supply of battery materials and to support a fast-paced energy transition, the EU needs to combine the development of recycling facilities with new primary metals supply. The CRMA as well as the NZIA are expected to improve competitive operating conditions for the batteries value chain in Europe. The Commissions ambition to identify priority projects, accelerate permitting procedures and facilitate new finance is a very welcome step to improve the speed and viability of new projects. An important step in the right direction is the pragmatic approach for a fast-track permitting to shorten the time for new material mining, processing and recycling projects. Making critical capacity available more rapidly and the provisions to prioritise projects for such streamlined accelerated permitting without undermining established EU environmental and social standards are key to ensure legal certainty. RECHARGE supports the requirements for authorities to prioritise strategic projects, including prescribed timelines for reaching a decision. On the other hand, a key element is missing from the Commissions proposed CRMA: A key issue slowing down the domestic development of a sustainable and competitive EU batteries value is incoherence and incompatibility between EU climate objectives and EU chemicals policy. Companies making long-term investments into new European mining, refining and recycling activities require regulatory certainty. Multiple legislative frameworks related to critical raw materials and battery manufacturing are interconnected: this includes the Industrial Emissions Directive, Batteries Regulation, ELV Directive, REACH Revision, Waste Framework Directive, Waste Shipments Regulation, Ecodesign for Sustainable Products Regulation as well as the upcoming European Waste Catalogue Revision. The CRMA benchmarks set for European capacities by 2030 need to become an overriding goal across these policies, so that the ambition can be truly met. Coherency is important between these policies to allow predictability for investment. In the here submitted paper, we provide our recommendations for amendments to the proposed CRMA based on the following priorities for RECHARGE: 1) Ensuring EU funding in addition/complementing State Aid; 2) Ensuring coherence with other EU legislation; 3) Careful assessment of the need for stockpiling, joint purchasing and company risk preparedness measures; 4) Boosting recycling capacities: recycling of material already in Europe ensures the stocks remain in the EU; 5) The calculation of the environmental footprint of CRMs is essential; 6) Ensuring the supply of CRMs from responsible sources with robust certification; 7) Permitting acceleration is welcome; 8) Establishing a fair and transparent calculation methodology and monitor progress towards reaching the benchmarks. Finally, what we need now is a speedy adoption of the CRM Act and the Net-Zero Industry Act to avoid a standstill of projects.
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European battery industry calls for more ambitious production targets

27 Jun 2023
Topic — The Net Zero Industry Act supports domestic manufacturing of clean energy technologies.
Message — RECHARGE requests a 1,000 GWh production target and more robust EU funding. They also want battery components included in the scope and better coordination with chemicals laws.123
Why — Increased funding and streamlined permits would improve the viability of new battery projects.4
Impact — Environmental and health advocates may see weakened enforcement of chemical safety regulations.5
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Meeting with Christian Ehler (Member of the European Parliament, Rapporteur)

25 May 2023 · NZIA

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur for opinion) and Transport and Environment (European Federation for Transport and Environment) and

22 May 2023 · Net-Zero Industry Act Stakeholder Hearing

Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton)

8 Sept 2022 · Batteries and REPowerEU

Meeting with Michal Wiezik (Member of the European Parliament, Shadow rapporteur)

6 Sept 2022 · Industrial Emissions Directive

Battery industry association urges fast-track permitting in emissions revision

22 Jun 2022
Topic — The consultation seeks views on updating EU legislation to reduce industrial pollution.
Message — RECHARGE calls for fast-track permitting for the entire battery supply chain. They demand that the Commission ensures no business-sensitive data is published.12
Why — Faster permitting and reduced regulatory overlaps would lower administrative costs and production delays.3
Impact — Environmental groups lose transparency if industry demands for increased data confidentiality are accepted.4
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Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur)

19 May 2022 · New Battery Regulation

Response to Modernising the EU’s batteries legislation

1 Mar 2021

The advanced rechargeable and lithium batteries value chain in Europe, as represented by RECHARGE, welcomes draft Regulation 2020/353 (COD) as an important step towards the common goal of setting the standard for sustainable, innovative and competitive batteries made in Europe: It recognizes the strategic role of batteries for decarbonization, strategic autonomy and societal prosperity, and generally incorporates important updates as concerns today’s market structures. We welcome the Regulation’s objective of creating coherence with other EU policy areas and regulatory frameworks, and the inclusion of important key sustainability pillars. Especially social due diligence and carbon intensity have the potential to strengthen batteries that have been designed and manufactured with the highest environmental and social conditions in place – provided that these requirements and their scope are correctly implemented. RECHARGE wants to stress the importance of transforming the current Batteries Directive into a European-wide regulation. This is key to ensuring a high degree of predictability and clarity for economic operators. However, the draft Batteries Regulation does not fully meet its objective of creating a future-proof legislative framework. A high level of complexity and critical overlaps risk jeopardizing the effectiveness of the Commission proposal. In light of “Better Regulation”, RECHARGE therefore proposes to: 1. ENSURE FEASIBLE TIMELINES: Given the strategic importance of the battery industry, a timely yet robust implementation of the new EU rules is crucial for this cornerstone legislation. Certain deadlines pose a real challenge to compliance. This is especially the case for establishing the calculation methodologies for carbon footprint, recycled content or for new recycling efficiencies – all subject to an early declaration obligation. Also, a grandfather clause is missing. 2. STRENGTHEN ENFORCEMENT AND LEVEL PLAYING FIELD: To ensure the effectiveness of the European battery rules, RECHARGE recommends incorporating a dedicated paragraph on enforcement. In addition, for the Batteries Regulation to successfully set the standard for environmentally and socially responsible batteries, all actors - in and outside of the EU - must be subject to the same requirements and conditions. 3. HOLD HIGH THE INDUSTRY’S EXTENSIVE SAFETY APPROACH: Safety is a key priority to the EU battery industry. We call on European policymakers to refrain from any wording that would encourage unqualified persons to alter a battery, and that contradicts existing safety standards. 4. HARMONIZE OVERLAPPING PROVISIONS WITH OTHER REGULATORY FRAMEWORKS: RECHARGE encourages EU policymakers to remove overlaps and give priority to overarching, horizontal legislation, such as the REACH and OSH chemicals management frameworks or UN safety legislation. 5. HARMONIZE OVERLAPPING PROVISIONS WITHIN THE BATTERIES REGULATION: Certain provisions risk creating over-regulation and unnecessary overlaps, such as multifold information and waste management provisions. 6. REDUCE COMPLEXITY BY FOCUSING ON REAL-BENEFIT PROVISIONS: The objective of this Regulation must be to work towards essential policy targets instead of creating an environment of control and obligations. Unfortunately, several provisions do not withstand the effectiveness test under real-world conditions, such as performance and durability criteria for industrial and electric vehicle batteries. Redundancies must be avoided. 7. REDUCE COMPLEXITY FOR NICHE AND SMALL-SERIES BATTERIES: Certain measures were clearly established around mass-volume (EV) batteries and now create a disproportionate administrative and cost burden on niche or small-series. Other measures are too technology-specific to be achievable for certain (niche) battery chemistries. For our full assessment and industry proposals, please download the RECHARGE position paper attached to this introduction statement.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

RECHARGE, the industry association for advanced rechargeable and lithium batteries in Europe, supports a revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II) to further increase the share of renewable energy in the European energy mix as outlined in the Energy System Integration Strategy. While a mix of many technologies is needed in Europe’s energy transition, we want to highlight that flexible storage solutions, such as batteries, have a vital role to play. We therefore encourage a better recognition of battery storage services in the revision of RED II. Battery storage systems are critical to ensuring a smooth electrical energy supply by balancing the grid during peak and low electricity production periods, providing a reliable and permanent interface between the production site and the electricity grid, and helping to regulate the voltage and frequency of the grid. Batteries have become substantial to limiting curtailment of excess energy and, hence, limiting energy waste. Further, renewables + storage has enabled a more decentralized and smarter electricity infrastructure that better enables the “utilization of local energy sources, increased local security of energy supply, shorter transport distances and reduced energy transmission losses.” Batteries are also a cost-effective storage solution. Electrification of transport, heating & cooling: A cost-effective and flexible electricity system is indeed important, especially to further encourage renewable energy use in other areas than just electricity generation. RECHARGE supports increased electrification of passenger and cargo transport based on a high share of renewable energy for the battery manufacturing and charging phase, to (a) reduce GHG emissions in the transport sector and (b) unlock the potential of the interconnection abilities of renewables + storage for other sectors such as buildings and industry. We believe that planned measures in the renewable energy (and other energy-related) legislation should further encourage innovative models such as sector coupling and vehicle-to-grid. Economic value: We agree with the Commission’s assessment that increased renewable energy targets will also have a positive impact on economic growth and investments by creating quality jobs and reducing dependence on non-European energy sources. The battery storage industry alone is expected to generate €210 billion new GDP and create some 1 million jobs by 2022. Incentivizing prosumers with storage systems: We welcome that in the current Renewable Energy Directive, especially article 21 § 2(b) , attention had been given to taxation and charging questions related to self-consumption in renewable energy installations with storage systems. Based on Directive (EU) 2019/944, article 15 § 5, RECHARGE encourages extended provisions for both self-consumption and prosumers with the aim of further incentivizing utility-scale and behind-the-meter storage solutions. Also, clarification is required regarding priority access for renewable energy that is fed into the grid, coming from either primary production or stored renewable energy (see Directive (EU) 2019/944, article 15 § 5(d). Clarification of guarantees of origin for energy from renewable sources: In relation to our work for the PEFCR (Product Environmental Footprint Category Rules) for rechargeable batteries, RECHARGE calls for additional clarification regarding guarantees of origin for energy from renewable sources (article 19) and the offsetting mechanisms applied. Guarantees of Origin must be a fair mechanism to reward companies using green energy while further incentivizing Member States to develop their renewables-based electricity infrastructure. Attached our full statement.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

RECHARGE, the industry association for advanced rechargeable and lithium batteries in Europe, welcomes the new legislative proposal for better substantiating green claims. RECHARGE promotes a legislative framework that helps establish meaningful environmental impact indicators based on (a) reliable, comparable and verifiable information, and (b) presented in a clear, specific, unambiguous and accurate manner. We encourage the Commission to implement a legal framework that would require companies “to make environmental claims related to the impacts covered by the PEFCR” (Option 3). If adapted to the specifics of each value chain, RECHARGE supports the PEFCR as a single, reliable tool to identify and assess important environmental impacts. Further, RECHARGE recommends to base mandatory environmental requirements in our industry on the carbon footprint indicator as established by the PEFCR. Our unique experience in identifying and assessing the environmental impacts of batteries based on the PEF has shown that a number of environmental impact categories are either of little relevance for batteries or not robust enough: - Some PEF datasets are incomplete and replaced by proxies - Complex components are simplified in secondary datasets - Models used for the calculation of some environmental impacts are of uneven quality, and will require further development and validation in order to become “fit for purpose” In turn, batteries can truly differentiate on the carbon footprint. A value-chain based environmental indicator, it is probably the most meaningful, credible and comparable differentiator in our industry. Carbon Footprint and Global Warming Potential are well known and understood by the consumer, which allows them to easily identify batteries with a superior environmental profile and energy efficiency rating. It also gives necessary signals to poorly performing industry actors with the potential to incentivize them to improve the carbon content of their product. RECHARGE believes that environmental claims for complex articles such as batteries should be based on a simplified PEF methodology using a harmonized and strong database. It is in this context that RECHARGE has recently relaunched the PEFCR for our products and prepares the ground for a strong industry benchmark. To achieve a harmonized approach for providing reliable environmental information and help consumers make informed purchase decisions, RECHARGE recommends communication provisions that are easy to implement, update and use. To that end, the advanced rechargeable and lithium batteries industry in Europe recommends information systems such as the product passport supported by either a QR code or a similar electronic marker that can provide a future-ready data service. Independent of the policy options presented in the Inception Impact Assessment, RECHARGE supports establishing an appropriate framework for the verification of Environmental Footprint profiles but wants to caution against mandatory monitoring and enforcement. Both the PEF methodology and related databases will first require real-world validation experience before mandatory obligations can be established and enforced. Besides the challenges posed by incomplete or simplified data, industry actors also lack experience in applying the PEFCR methodology and will need some guidance. Especially for complex articles with multi-level value chains, such as batteries, this is a major subject of concern. We also note that there is not yet a full alignment with other initiatives relying on the assessment of environmental performance (e.g. the Emissions Trading Scheme benchmarking, or international standards such as the Global Reporting Initiative) and therefore request that the European Commission provides clarification regarding the interaction and overlaps, as well as possibility for coordination and/or harmonization between these many initiatives.
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Response to Modernising the EU’s batteries legislation

29 Jun 2020

The advanced rechargeable and lithium batteries industry, as represented by RECHARGE, welcomes the adaption of the existing Directive to a more comprehensive regulation for batteries. We are convinced that improving the legislative landscape impacting batteries, and working towards better coherence across the regulatory spectrum, is key to establishing that sustainable and competitive battery industry as aspired by the European Commission. The Commission’s proposal for a modernized battery legislation is a unique opportunity to deliver at product level on the EU’s 2050 climate-neutrality and industrial leadership objectives by better demonstrating the increasing role of batteries in a decarbonized Europe, and helping to establish a level playing field due to legislative adjustments that create a net environmental and social benefit. RECHARGE wants to stress the need to eliminate overlaps with other EU legislation and to focus legal measures on building a fair basis with international competition. We welcome the recognition of the carbon footprint and social responsibility across the value chain as the essential sustainability indicators for batteries. For consumers to effectively use sustainability indicators and make informed purchase decisions, meaningful, clear, simple and consumer-oriented communication provisions are needed. Irrelevant information must be avoided. Generally, we want to advise against an overload of measures if they reduce the innovation potential and competitiveness of the EU battery value chain. We welcome the expansion of the legislative scope to a broader battery technology spectrum, however, allowing to better capture new or emerging technologies in the future. We also welcome the Commission’s recognition of the use of hazardous substances in battery cell manufacturing, acknowledging the technical limitations to substitution in our sector and the industry’s efforts towards the Union’s toxic-free environment ambition. The advanced rechargeable and lithium batteries industry in Europe has successfully implemented an unsurpassed emission and dissipation control system for material handling in both the production and recycling phase. Because chemical substances are contained within sealed units, the use of these batteries does not pose any harm to health or the environment either. In turn, a legislative framework that prohibited or restricted certain types of battery chemicals would bring investments in the EU cell manufacturing sector to an immediate halt, threatening the creation of some 280,000 European jobs in the coming 5-8 years. It is also in this context that RECHARGE wants to caution against the premature implementation of a recycled content obligation. Like recycling targets, minimum recycled content requirements intend to address resource savings and carbon emission credits from using secondary raw materials. But the burdens associated with these requirements risk jeopardizing the competitiveness of European batteries, and the environmental benefits are reportedly very limited. We are equally concerned about the proposal to phase out primary batteries. We understand the trend to restrict single-use products but want to highlight that many primary batteries are not disposable products with a short lifetime. They can last up to 20 years or are designed to serve for the entire use life of the appliance they power. Moreover, in many instances, replacing these batteries is technically not feasible and would not result in an improved environmental footprint. RECHARGE calls upon the European Commission to consider legislative measures that are balanced, comprehensive, meaningful and apply to both imported as well as European batteries. The legislation should support establishing a prosperous European battery industry contributing to the achievements of the emission reduction targets and capable of competition with strong, existing markets outside of the EU, on a fair base.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Chemicals are essential to our industries, and societies as such: To reduce greenhouse gas emissions from human activity while safeguarding our way of life, we depend on smart and viable technological answers based on advanced, sophisticated and complex products. The advanced rechargeable and lithium batteries industry in Europe, as represented by RECHARGE, calls for a chemicals policy framework that effectively combines the EU’s various sustainability and technological leadership objectives on a strong scientific evidence base. We encourage legislative measures that are balanced, comprehensive, meaningful and apply to both imported as well as European batteries. The EU’s chemicals framework should support both a prosperous European industry and environmental leadership. In this regard, RECHARGE welcomes: o Harmonization efforts between the different legislative pieces and better coherence with other EU policy areas, as well as the ambition to implement a sound chemicals, product and waste management legislation that simplifies the current framework, reduces overlaps and helps drive long-term industrial investments. The one substance – one assessment approach will be pivotal to this ambition, as will be the Better Regulation principle always opting for the regulation that has proven to best protect health and the environment from potential risks stemming from chemicals. o The promotion of strategic autonomy for chemicals that can be sourced and produced in the European Union. We support increased efforts in fostering sustainable materials extraction and chemicals manufacturing based in Europe. o The Commission’s efforts to not limit the Chemicals Roadmap to European chemicals and products but to create a level playing field with imports. Within the context of the Commission’s zero-pollution ambition, the advanced rechargeable and lithium batteries industry in Europe supports the non-toxic environment initiative when focused on limiting direct harm to health and the environment from final products using chemicals. We want to caution against an unrealistic ambition to phase out chemicals because of their simple classification, however. Substitution of substances is often technically not feasible. In fact, in most applications the substances used are selected because of their unique chemical properties. Substitution must therefore be limited to areas where this is technically feasible at industrial scale. Our industry is particularly concerned by the belief that non-chemical alternatives could increase the safety of certain products. In fact, many non-chemical alternatives are highly engineered materials. Long-term monitoring of their impact on health and the environment is often missing. In turn, the advanced rechargeable and lithium batteries industry brings more than 100 years of successful chemicals use to the debate. Our products use different substances, incl. hazardous ones, to generate the electro-chemical features needed for decarbonized energy storage, e-mobility or everyday communication devices. Chemicals are safely contained within the sealed units of our products and are increasingly managed by sophisticated electronic management systems. Using these products does not pose a risk to human beings and the environment. Risks associated with the potential exposure to chemicals are limited to the workplace (manufacturing or waste treatment). Here, the high European standards for worker and environmental protection as well as advanced factory design have already contributed to the achievement of an unsurpassed emission and dissipation control system, mitigating any risks from substances of concern. At RECHARGE we believe that the European chemicals strategy should therefore better differentiate between exposure at the workplace, and exposure to consumers and the environment during the use phase. A risk control approach must be at the center of this strategy.
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Response to Climate Law

31 Jan 2020

RECHARGE welcomes the initiatives of the European Commission aiming to create a socially just, climate-neutral, competitive, striving and innovative European economy and society. RECHARGE will do its utmost to support the goals of the Climate Law Roadmap and will remain committed to developing a sustainable battery value chain designed to meet the needs of the future (for more information on our roadmap for Batteries fit for the EU market, read our position paper here https://www.rechargebatteries.org/wp-content/uploads/2019/12/Position-Paper-RECHARGE_Batteries-fit-for-Europe_2019.pdf). 2020 law-making will be crucial to the execution of the Strategic Action Plan for Batteries, which aims at creating an innovative, sustainable and competitive battery 'ecosystem' in Europe. The Climate Law Roadmap’s ambitions will be pivotal to such ecosystem. For the Climate Law, and more generally speaking, the Commission’s toolbox for reducing CO2 emissions while ensuring a society-oriented mobility infrastructure and meeting the increasing need for electricity, we expect European batteries to become a fundamental cornerstone. As such we want to applaud the political commitment to put batteries at the heart of the EU’s climate-neutrality roadmap. Batteries truly have become a flagship industry for a future-ready EU that is built on social justness, decarbonization, economic prosperity and technological competitiveness: → Advanced rechargeable batteries are a key enabler for the transition towards low-emission mobility and decarbonised energy generation. Without them, the target of a climate-neutral economy by 2050 and the 2°C Paris Agreement goal cannot conceivably be reached. → Batteries’ applications in the automotive, industrial vehicles and energy sectors are key tools for this transition. In the transport sector, the hybridisation and electrification of vehicles reduce CO2 emissions, while the use of batteries in industrial vehicles supports both decarbonisation and noise reduction. → In the energy sector, batteries are necessary to store renewable energy and contribute to the stability of the electrical grid, playing an important enabling role in a decarbonised electricity infrastructure. → Batteries have become a significant job engine for millions of people around the world. In combination with renewable energy generation, batteries have paved the way to electricity access for rural and remote areas too, bringing power to some 600 million people. What’s more, batteries power everyday applications, such as smartphones, tablets, power tools, and robots. Their social impact can hence not be neglected. At the same time, we want to seek the further support from an EU strategy that enables industrial competitiveness at all levels of the advanced rechargeable battery value chain, from raw materials sourcing and equipment manufacturing, to cell and battery production, through to OEM manufacturing and end-of-life management. Long-term job creation, next-generation technologies, world-leading product stewardship, continuous industrial investment – these are the results of coherent policy interests, the creation of an international level playing field, sensible policy-making and access. Access to know-how, access to funding and access to important resources and equipment. Hence, for the EU to achieve its climate as well as industrial leadership goals, RECHARGE hopes that the Climate Law is compatible with both. Already the Strategic Action Plan for Batteries calls for a coherent regulatory framework. The advanced rechargeable and lithium batteries industry in Europe, represented by RECHARGE, wants to stress that very need.
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Response to Sustainability requirements for batteries

6 Feb 2019

Ecodesign Directive for Batteries RECHARGE View on Criteria for Sustainable Batteries Introduction RECHARGE acknowledges this effort towards a sustainable industrial policy for batteries, however would like to stress that the quality of the work should not be undermined in favor of a quicker legislative process. Particularly, the scope of the ECODESIGN for batteries should be enlarged to include the impacts from cradle to grave, throughout all phases of a battery life from manufacturing (including the supply chain), use and to the end of life. RECHARGE suggests some proposals, based on the key takeaways from RECHARGE’s internal working groups, and the project for batteries within the Commission pilot “Product Environmental Footprint”. Key priorities for sustainability requirements for batteries  A result-oriented Ecodesign directive for batteries, focused on recognized and measurable impacts. As an overall recommendation, RECHARGE stresses that the Ecodesign directive should not impose requirements on the very technical choices related to design and the process, due to the infancy stage of batteries designs and industry processes for e-mobility, as many competing solutions are foreseen to increase the battery performance, and many more will be identified.  Raw materials: Ensure the setup of take back and recycling systems. Market projections for 2030 point to volumes up to 400 GWh or more of batteries placed on the market per year, which equates to approx. 1.6 million tons a year. High performance Li-ion batteries require the use of some rare metals with a limited supply. It is therefore necessary to establish take back and recycling systems, so that this source of secondary raw materials becomes available in Europe. It is however important to note that within the EU, an Extended Producer Responsibility regime is already in place thanks to the battery directive, whereby all used batteries must be taken back by Producers and recycled. This directive is currently undergoing a revision process, which could be used to further improve this instrument, should the need arise. For example, we recommend to recycle metals such as cobalt and nickel in Li-ion batteries “to the highest degree that is technically feasible while avoiding excessive costs”).  Climate change: CO2 eq content of finished e-mobility batteries as a criterion to discriminate across products placed on the EU market Electrification of road vehicle transportation aims at improving air quality within urban areas and reducing CO2 emissions. The manufacturing of a battery, which weighs up to 40% of the vehicle for a BEV, is a new source of CO2 emissions, and should be a component of the assessment the European Commission lays out (see annex). The DG Environment PEF, despite still in need of much improvement and simplification, highlighted that batteries impact can differ significantly across models on this criterion, and demonstrated that a large fraction of impacts arises from metals extraction and refining as well as in the manufacturing of other components, whereas actual manufacturing operations (under the roof of the battery maker) and use in the vehicle have relatively limited impacts (see annex). CO2 eq content of finished e-mobility batteries, normalized by total kWh output throughout the life of the battery, should be a critical criterion to discriminate across products placed on the EU. Furthermore, low performing products should not be placed on the market, and identification should be implemented to differentiate and incentivize higher performance products.  CSR principles: Encourage the industry to source from supply chains located in countries implementing the 8 ILO conventions and truly apply them within their facilities.  Implementation principles in line with Understandable, Standardized, Accurate, Discriminating and Auditable Standards
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Response to Common chargers for mobile phones and similar devices

30 Jan 2019

RECHARGE answer to the Commission Inception Impact Assessment. Introduction The European Commission has requested feedback on the intended initiative aiming at standardizing the chargers of various electronic devices. RECHARGE acknowledges the interest of assessing the impact of standardization and availability of a common charger. Based on RECHARGE’s expertise acquired during the Commission pilot project for Product Environmental Footprint of batteries, RECHARGE would like to suggest some recommendations on the global benefit of this approach. Key Batteries performance recommendations Batteries life duration depends significantly on the charging control parameters, such as maximum current, minimum and maximum voltage, and temperature limitation. These parameters are controlled through electric and electronic components, either placed in the charger or in the battery itself. To provide benefit for users and the environment, the common charger approach should:  Ensure to not generate a reduction of the battery service, or even a safety incident A non-optimized charging of the battery can significantly reduce the life duration of the battery, up to 30% or more. The risk of a lack of technical compliance of a common charger to various batteries technologies should be addressed, and particularly for various type of devices, as indicated in the possible extension of the scope: “As an indication, equipment that could fall under scope of this initiative could be tablets, cameras, portable GPS devices, radio controlled toys and any other devices with compatible current requirements”. Moreover, if the charging conditions are too different from the specification, the charging process can eventually lead to irreversible battery damage, or fire risk. Cases of safety incidents, due insufficient quality or technical specification of the chargers (i.e. hoverboards and e-cigarettes), or counterfeit products, have already been identified and should be prevented.  Prove to not increase the global environmental impact of the device, due to a potentially reduced life duration of the battery The environmental impacts of the representative use case should be compared when using a common charger versus a charger optimized for the device -including potential battery life reduction, and/or additive charger features for multiple battery types- to verify the benefit of the proposal. About RECHARGE aisbl is the Advanced Rechargeable and Lithium Battery Association representing the specific interests of the Rechargeable Battery Industry in Europe. RECHARGE’s mission is to promote the value of advanced rechargeable batteries through their life cycle. RECHARGE’s Members include Rechargeable Battery Manufacturers, Original Equipment Manufacturers, Rechargeable Batteries Recyclers and Raw materials suppliers to the Battery Industry. Contact cchanson@rechargebatteries.org
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and EUROMETAUX and Association of European Automotive and Industrial Battery Manufacturers

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

Response to Carcinogens 3rd wave of amendments

1 Jun 2018

RECHARGE and EUROBAT represent the EU industry for nickel cadmium batteries manufacturing and recycling. A safe work place for workers exposed to cadmium based on the SCOEL 2010 Recommendation: European plants which manufacture nickel-cadmium batteries have worked with the International Cadmium Association (ICdA) to embrace and implement the health-based exposure limits put forth in the SCOEL 2010 Recommendation. As explained in this SCOEL 2010 Recommendation, adequate protection against: • LOCAL ADVERSE EFFECTS (to the lung), which are triggered by cadmium inhalation, requires compliance with an air limit value (OEL) of 4 µg/m3 (respirable fraction), • SYSTEMIC ADVERSE EFFECTS (essentially to the kidney), which are triggered by both cadmium inhalation and ingestion, requires compliance with a urinary biological limit value (BLV) of 2µg Cd/g creatinine. With the training and support of ICdA, these limit values have been implemented in all European nickel-cadmium battery plants, under the responsibility of management for OEL implementation, and responsibility of the occupational doctor for BLV monitoring. SCOEL 2017 confirmation of this approach: In its 2017 Opinion , SCOEL confirmed the validity of this approach and highlighted that both the BLV and the OEL must be implemented in conjunction: “Such an 8h-TWA value of 4 µg Cd/m3 (as derived by SCOEL in 2010) must be seen in close conjunction with the derived BLV, as both refer to and are protective for different toxicity endpoints of relevance (local and systemic). Thus, implementation of both elements of the OEL- TWA and BLV- are of critical importance. However, an isolated OEL (8-h TWA) of 4 µg/m3 [respirable fraction] not linked with a BLV would not appear being equally protective against the systemic nephrotoxicity of Cd” SCOEL stated further that if no urinary cadmium biomonitoring is in place: “In this case, an OEL (8h TWA) of 1 µg Cd/m3 (inhalable fraction) can be proposed”. A Commission proposal which is based on the less protective approach: It must be noted that this second approach (OEL only) retained by the Commission is less effective than the original approach (OEL and BLV) because: • It ignores ingestion, which is one of the two routes of exposure which may lead to an adverse effect to the kidney. Moreover, ingestion is a very significant exposure route relative to inhalation when the OEL is complied with, • Compliance with an air limit is checked by taking a limited number of air measurements, from which the general compliance status of the plant is extrapolated by means of a statistical analysis. Therefore, it only allows for a statistical protection of workers. Whereas biomonitoring, which is conducted on every single worker individually, allows for the occupational doctor to review each worker’s health in a very accurate way. Joint position of EUROBAT and RECHARGE: Both associations respectfully request that the Council and Member States amend the Commission Proposal which is based on a truncated conclusion of the SCOEL 2017 Opinion, and that they incorporate this SCOEL 2017 Opinion in its entirety by taking into full consideration the benefits of bio-monitoring: “For plants where a urinary biomonitoring program is in place under the supervision of the occupational doctor, B-OEL = 4 µg/m3 (respirable fraction) is applicable”
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