Brussels — Eurobat, the Association of European manufacturers of automotive and industrial batteries, welcomes the initiative of the European Commission to evaluate the Directive 2006/66 on batteries which is one of the central pieces of EU legislation for the association`s sector. As regards the Roadmap, Eurobat underlines three points mentioned in the document that the association considers to be of equal importance.
1. Competitiveness of the EU battery market
Eurobat is the association of European automotive and industrial battery manufacturers and its members produce batteries of all types of chemistry in Europe, Middle East and Africa. The clear majority of these members has a European production foot-print and is marketing their products at a global level. Eurobat therefore welcomes that the evaluation will also assess the impact of the provisions in the Directive on the competitiveness of the Batteries Industry within the EU.
The battery market is very dynamic with many recent technological and market developments, and we believe that the Battery Directive should be made fit for these fast-paced changes. Any revised legal text should be able to respond more quickly to any such new development. The objective must be to put in place a regulatory level-playing field for all battery technologies while, at the same time, ensuring business certainty for battery producers and all operators in the battery value chain. For the evaluation process this means that administrative principles (such as producer responsibility, financing or reporting requirements) should be designed in a way to guarantee stability for the market, while technical elements (such as addressing emerging battery technologies) should be flexible to satisfy the requirements of sustainable development.
2. Link with EU’s ambition to promote a circular economy
Eurobat welcomes the reference to circular economy in the EC Roadmap. The association`s sector is among the frontrunners when it comes to circular economy, as almost all automotive and industrial batteries are collected at end-of-life. Lead-based batteries, for example, are to almost 100% collected and recycled. In order to further improve collection and recycling processes and to guarantee the safety of these processes, Eurobat asks to include a reference in the Batteries Directive to the forthcoming IEC standard (IEC 62902) on labelling of batteries according to their chemistry. The objective of this suggestion is not to replace the current labelling of automotive and industrial batteries (‚crossed-out wheeled dust bin), but to add colored background labels to facilitate collection, sorting and, ultimately, treatment of these batteries. The association also believes that it is important to assess the impacts of the second-life of batteries on the whole life-cycle of batteries, including the end-of-life stage, from a producer responsibility and warranty point of view.
3. Legal and regulatory coherence with other pieces of EU legislation
Eurobat deems it as essential to assess and improve the legal and regulatory coherence of the Batteries Directive with other pieces of EU legislation like End-of-Life Vehicles Directive, REACH etc.. The Batteries Directive should be the primary legislative instrument used to regulate environmental, health and safety aspects of battery manufacturing, use and waste. This means that the overlaps between the Batteries Directive, the REACH Regulation and the End-of-Life Vehicles Directive should be identified and addressed to ensure that the legislative framework impacting EU battery technologies is coherent and simplified.
Fundamentally Eurobat believes that decisions about which battery chemistry to use for a given application should be left to the markets, meaning producers of batteries and those using them. Any decision to substitute one battery chemistry for another must first include consideration of required performance (as these products are often used as back-up equipment providing safety functionalities), the analysis of the environmental impact from cradle to grave along with a consideration of socio-economic aspects.
Source: Eurobat – Association of European Automotive and Industrial Battery Manufacturers