Joint Industry Position Paper on the Batteries Regulation

The industrial associations covering different aspects of the battery value chain, from raw materials supply to battery manufacturing, users of batteries, and recyclers express their concern about key elements considered in ongoing debates in the European Parliament and the Council on the Batteries Regulation proposal, and provide recommendations for achieving shared goals.

Our associations have welcomed the publication of the draft Batteries Regulation in December 2020 as crucial to regulate the battery sector by closing gaps in the existing framework. We support the overarching objective to produce sustainable batteries in Europe, reconciling environmental considerations and competitiveness needs.

As recognized in the EU Strategic Action Plan on Batteries, batteries are a fundamental enabler to the decarbonization of several economic sectors, and an appropriate legislative framework is needed to foster a strong European industry. We are concerned that several items under negotiation on the Batteries Regulation risk slowing down or endangering this needed transition, for reasons further detailed in this paper.

In recent months, we have identified several areas to build upon the European Commission’s first proposal, for example to address unrealistic lead times or requirements that would hamper the innovative and fast-paced profile of the battery industry.

We are concerned that in several cases amendments, under discussion by the co-legislators, go in the opposite direction. Several over ambitious proposals – whose intention might be to support a sustainable and competitive EU battery industry – unfortunately overlook specificities of battery types and their applications, or dynamics of the rapidly growing battery market.

Increased targets, proposals for tighter schedules or scope extensions, if not based on impact assessments or some form of in-depth analysis, might have negative effects on the competitiveness of the EU industry and impede the shift towards electrification in the transport, energy and industrial sectors. Consequently, the result would go against the Strategic Action Plan on Batteries as well the EU Green Deal objectives and the Fit for 55 ambition.

This paper provides five key recommendations of achieving a robust legislation that will embrace future developments of sustainable and innovative batteries:

  • Recycled content
  • Design requirements and second life
  • Material recovery targets
  • The scope of carbon footprint and of performance and durability
  • Restriction of hazardous substances


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