Batteries and waste batteries

SOMO urges the EC to address the following recommendations: • Reducing mineral and energy demand. The EC should prioritize reducing the mineral and energy demand of passenger road transport in absolute terms. To do so, the EU should support and promote strategies towards car-sharing, ride-sharing and public transport.

When introducing new requirements as in the battery legislation, it is important that there is a clear environmental benefit with the measures and that the impact assessment that the Commission is planning for is thorough.

EGARA is the European association of car dismantlers. We collect ELV’s rather than batteries and we take the batteries out of ELV’s according to the ELV Directive. For this we deal with mainly EV batteries, Automotive batteries and smaller system (backup) batteries (read: E-call, tire pressure, seat heating etc.).

BVES position paper: EU Regulation proposal concerning batteries and waste batteries - COM(2020) 798/3 The EU Batteries Regulation will shape the Battery market in the forthcoming decade. The BVES welcomes the approach of the EU Commission to deliver a regulatory framework which supports key objectives of the EU Green Deal boosting the efficient use of resources by moving to a circular economy and increase the…

The European Environmental Bureau (EEB) welcomes the proposal presented by the EC, including the the switch from a directive to a regulation which is necessary for a consistent implementation across all Member States, improving harmonisation and legal certainty.

Friends of the Earth Norway appreciate the opportunity to comment on the proposal, which has implications for the EEA-Agreement, and strongly supports regulation of battery production and materials for battery production.

We are referring to article 52 page 84. Our opinion is that base batteries should be handled by producers and other authorized companies, not only producers. This article must not lead to producers only taking over the base batteries without paying any fees.

EDF welcomes the proposal for the new Battery Regulation as an opportunity to create a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy and Circular Economy Action Plan. See the full position paper attached

The TÜV-Association welcomes the EU Commissions initiative to modernise EU legislation on batteries. Batteries are becoming more and more essential for key sectors of our economy and society such as mobility, energy and communications. In order to fully tap the potential of batteries for environmental and climate protection, their own ecological and social footprint must be as low as possible.

This submission is made on behalf of four European NGOs: ECOS, EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany, and Transport & Environment, all with an interest in the development of an environmentally sustainable battery value chain in Europe.

Automotive Cells Company (ACC)/Public position Proposal for a Regulation on batteries 2020/353, replacing Directive 2006/66/EC and amending Regulation (EU) 2019/1020 The necessary energy transition required by the European Green Pact increases the need for batteries for the electrification of vehicles and makes this growing market a strategic axis for Europe.

Filed in French · English published by the European Commission

Earthworks, a US-based NGO supporting mining-affected communities globally, welcomes the EC proposal for a Battery Regulation and strongly supports the need for the transition to sustainable mobility. Due Diligence The mandatory due diligence set out in Art.39 is a necessary step in beginning to address the wide range of human rights and environmental abuses along the battery metals supply chain.

Eurometaux, representing the European metals industry, recognises the major work ahead to deliver on EU’s ambition for batteries to help achieve the European Green Deal. Our members, producing and recycling battery metals (e.g.

ECOS welcomes the European Commission’s proposal for a new Regulation on batteries and waste batteries (replacing the current Battery Directive) and is pleased to contribute to the consultation on this matter. Together with other European NGOs, namely the EEB (The European Environmental Bureau), Deutsche Umwelthilfe (DUH – Environmental Action Germany), and Transport & Environment, we have developed a joint paper…

Schneider Electric is the global leader for energy and automation digital solutions for efficiency and sustainability. We combine world-leading energy technologies, real-time automation, software and services into integrated solutions for Homes, Buildings, Data Centers, Infrastructure and Industries.

The CEA welcomes the publication by the European Commission of its draft regulation on spent batteries and batteries. This project contains many positive developments. Other aspects would need to be completed and deepened. CEA supports the proposal to create a “passport” for batteries to transfer battery information throughout its lifecycle.

Filed in French · English published by the European Commission

The Nickel Institute takes note of the European Commission proposal for an EU battery regulation as published on 9th December 2020. Nickel producers are at the beginning and at the end of the battery value chain. Our member companies provide raw materials for battery technologies and recycle those once they reach the end of the life.

Cummins supports the effort to modernize the existing Batteries Directive through tough, clear and enforceable regulation. It is Cummins’ opinion that such regulation is not only helpful to human health and the environment, but also enables fair trade and a level playing field in terms of market access.

Automotive suppliers are pleased to provide feedback on the proposal for a regulation on batteries and accumulators and waste batteries and accumulators replacing and repealing directive 2006/66/EU. CLEPA represents over 3.000 companies supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, investing over 25 billion euros yearly in research and development and…

(See document attached for full response)The Finnish Association for Nature Conservation (FANC) is the major non-governmental organisation for environmental protection and nature conservation in Finland. It has been a frontrunner in Finland’s environmental affairs since 1938.

Filed in Finnish · English published by the European Commission

11.11.11 welcomes the European Commission’s proposal for a Battery Regulation and strongly supports the need for the transition to sustainable mobility to respect human rights and stay well within planetary boundaries. Our feedback focuses on the European Commission’s proposal to install human rights and environmental due diligence for economic operators in the battery chain in the European Union (Article 39).

Duracell welcomes the European Commission’s proposal for a regulation on Batteries & Waste Batteries for which we would like to provide our perspective with focus on a)The Battery Quality Standard (Performance & Durability Requirements) and b)Collection targets for waste portable batteries (visible fees).

EdEn welcomes the Commission’s proposal for a Regulation on batteries and waste batteries. We believe this proposal is an important step in reducing the environmental footprint of batteries throughout their whole life-cycle.

[ See document attached for full response] Equinor supports the European Green Deal objectives and welcomes the proposal to review the European Batteries Directive, with the aim of ensuring a sustainable and competitive value chain for batteries and of promoting a strong and innovative EU market for batteries.

The European Fire Safety Alliance (EuroFSA) is an independent alliance of fire professionals and exists to reduce the risk from fire. The EuroFSA has developed the very first evidence based European Fire Safety Action Plan, defining 10 actions that will improve fire safety in Europe (a result of research, the opinion of hundreds of fire safety experts and the best practices across Europe).

Hydro welcomes the proposal from the Commission for a European battery regulation and in general supports the improvements of sustainability and transparency of the battery value chain. Key messages: • Targets and timelines should be ambitious, but realistic and achievable.

The Natural Resource Governance Institute works in mineral-rich countries globally to promote accountability. We welcome the Battery Regulation proposal including its requirement for economic operators to establish due diligence policies in line with international standards for rechargeable industrial and electric vehicles batteries.

ACCIONA appreciates the European Commission’s proposal to achieve an improved and more harmonized rules framework for batteries across the EU. Battery development and production are strategic for Europe in the context of the clean energy transition.

The Platform welcomes the proposal for a Battery Regulation and strongly supports the need for modernisation of the existing batteries legislation. It must ensure harmonisation in the internal market and facilitate an accelerated shift to electrified mobility by engaging all parts of the battery supply chain.

The Platform welcomes the proposal for a Battery Regulation and strongly supports the need for modernisation of the existing batteries legislation. It must ensure harmonisation in the internal market and facilitate an accelerated shift to electrified mobility by engaging all parts of the battery supply chain.

The Confederation of Swedish Enterprise supports the Commission's work on sustainable products, in accordance with the Circular Economy Action Plan. The Swedish business community is already at the forefront of this work, and wishes to play a leading role in developing and contributing constructively to the European Commission's work on the topic.

EGEC views on Modernising the EU’s Batteries legislation EGEC, the voice of the European geothermal industry, is a not-for-profit association representing the entire value-chain of the industry across 28 countries.

Deutsche Umwelthilfe (DUH – Environmental Action Germany) is a recognised environmental and consumer protection association in Germany that has been actively campaigning for the preservation of natural resources and consumer concerns since 1975. DUH is politically independent, non-profit, has the right to sue and is active at national and European level.

ACCIONA appreciates the European Commission’s proposal to achieve an improved and more harmonized rules framework for batteries across the EU. Battery development and production are strategic for Europe in the context of the clean energy transition.

The Congo is not for sale anti-corruption coalition welcomes the EU Battery Regulation Proposal (“the Proposal”) and its requirement for battery producers to carry out due diligence for various risks in their mineral supply chain (art. 39). We regret however that the proposed risks do not include corruption and other financial crimes, as provided in prevailing OECD standards and other EU sectoral regulations.

Scania welcomes the proposal from the European Commission as batteries and battery electric vehicles will play a crucial role in reaching a climate-neutral Europe. Scania is committed to lead the shift towards a sustainable transport system. By 2030, Scania estimates that 50% of its total vehicle sales volumes will be electrified.

HWE welcomes the objectives seeked by the Commission’ s proposal for a regulation concerning batteries and waste batteries to reach competitiveness, circularity and protection of health and the environment. As such, the current proposal is part of the EU Green Deal, by striving to conciliate functioning of the internal market and a zero pollution ambition for a toxic- free environment.

The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community which are users of industrial storage batteries and are positioned downstream of both production and manufacturing.

European Recycling Platform (ERP) very much welcomes the European Commission’s proposal for a new Batteries Regulation and its overall objective to promote a competitive, circular and sustainable value chain for batteries in Europe.

France Industrie welcomes the European Commission's proposal for a regulation and its integrated approach as it will allow much more efficient recycling of batteries used within the European Union. This initiative will also enable the emergence of a genuine European expertise through the development of a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy.

DKE, the German Commission for Electrical, Electronic & Information Technologies of DIN and VDE, welcomes the new EU proposal of Regulation on batteries and waste batteries that should allow to position EU industry leadership as frontrunner in terms of green and technologically advanced batteries.

Campine Recycling welcomes the new proposal as a new step in harmonizing the Battery recycling. The recommendations for our industry are collected and summarized by the International Lead association, with our full commitment and input. With our answer, we want to give some detailed background information to stress the importance of a well defined recycling efficiency rate.

Under Chapter 1 (General provisions), Article 1 of the proposed regulation it states, “This Regulation shall not apply to batteries in: (a) equipment connected with the protection of Member States' essential security interests, arms, munitions and war material, with the exclusion of products that are not intended for specifically military purposes”.

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…

WEEE Ireland, on behalf of our Members and with our Eucobat colleagues, welcomes the European Commission’s initiative to adapt and modernise the legal framework for the entire life cycle of batteries, which are one of the key enablers for sustainable development and green mobility, clean energy and climate neutrality, contributing to the Green Deal objectives.

Orano would like to thank the European Commission for having launched, since 2017, a dynamic initiative aiming at setting a more sustainable and more competitive European battery industry. The proposal for a regulation presented in December 2020 to revise the current legislative framework (2020/353) should contribute to meet the growing demand of batteries in the EU, while minimizing their environmental impacts.

Norsirk AS is a producer responsibility organisation (PRO) for batteries in Norway. We have the following comments to the proposal: - Article 2(1) Definitions: There are electrical devices called “hybrid supercapacitors”. The commission should evaluate if these devices should be included in the regulation.

Boliden supports high ambitions for a sustainable transition to build up a strong industry for electric vehicles in the EU and welcomes the new proposed battery regulation. As one of Europe’s largest producer of essential metals for the green transition, Boliden will have an important role in providing the EU market with copper, nickel, zinc, lead, cobalt and other metals with strategic importance for the EU.

VEOLIA is the global leader in optimised resource management. VEOLIA designs and provides water, waste and energy management solutions. With the number of electric vehicles on the road around the world expected to increase from eight million in 2020 to 116 million by 2030, access to raw materials will become a strategic challenge.

ANIE is the Italian Federation of electrotechnical and electronic industries that represents more than 1,500 companies with an aggregate turnover (at the end of 2019) of 84 billion euros and 500,000 workers. The producers of batteries and accumulators represented by ANIE has an aggregate turnover of 800 million euros and 2000 employees.

1. We consider that industrial battery definition should include, as per present situation, professional use batteries or batteries include in professional electric and electronic equipment. 2. 65% target based on 3 last years POM (present year included) might be a correct target for general use batteries but not so much for batteries included in EEE where lifespan can last 4-7 years.

VEOLIA is the global leader in optimised resource management. VEOLIA designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries. With the number of electric vehicles on the road around the world expected to increase from eight million in 2020 to 116 million by 2030, access to raw materials will become a strategic challenge.

MedTech Europe supports the European Commission’s ambition to ensure a competitive, circular, sustainable and safe value chain for all batteries placed on the EU market. MedTech Europe considers the proposed Regulation a reasonable renewal of the existing Battery Directive.

FEAD welcomes the proposal. Our main comments to it: -Lack of a mandatory deposit refund system Incorrectly disposed Li batteries pose a high risk to people and the environment. It is necessary to return 100% Li batteries from a wide variety of waste streams to the battery collection.This can only be achieved through a mandatory return for particularly critical material flows, in addition to a high collection rate…

We, the BMW Group, are convinced that Europe and the European Economy can take a globally leading role in advancing climate change mitigation. As a globally acting company the BMW Group promotes for global decarbonisation and the implementation of human rights and sustainability standards in the supply chain.

The European Copper Institute (ECI) has read and welcomes the European Commission (EC) proposal for a new Batteries Regulation, COM(2020) 798/3. This is an ambitious step forward in the direction set by the Strategic Plan on Batteries.

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.

Mr Suez welcomed the proposal for a regulation on batteries and scrap batteries. We fully support the increased ambition of battery recycling. We have some comments and questions: Waste classification of EV batteries: (list of wastes — Decision 2000/532/EC) o Waste status of electric vehicle batteries is an important element in ensuring the integrity and safety of recycling throughout its stages (collection…

Filed in French · English published by the European Commission

We welcome the European Union’s efforts to increase the overall sustainability of batteries. We support the level of ambition of the regulation as well as its layout, to regulate every single step in the life cycle of a battery. We understand that, in order to be as effective as possible, the regulation aims to be extensive in scope, covering a wide range of battery applications.

Beyonder AS is a Norwegain high power battery cell manufacturer in the scale-up phase. We welcome the proposal from the European Commission for a new Battery regulation, COM (2929) 798/3 (the "Proposal"), and agrees that the clean energy transition calls for an overarching legislative framework for all types of batteries.

The Motorcycle Industry in Europe (ACEM) would like to hereby provide its initial assessment and comments on the European Commission proposal for a new Batteries Regulation. ACEM represents manufacturers of mopeds, motorcycles, three-wheelers and quadricycles in Europe. Its membership includes 18 manufacturing companies as well as 20 motorcycle industry associations in 17 different European countries.

Nissan Motor Co., Ltd. is working on promoting Electric Vehicles in order to pursue a zero emission mobility society. Furthermore, Nissan has set the goal to achieve carbon neutrality across the company’s operations and the life cycle of its products by 2050.

Cefic representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

The Finnish battery producer organisation Recser Oy appreciates the opportunity to give a feedback on the proposal for a regulation concerning batteries and waste batteries. In general, we welcome the proposal and support the chosen method of considering the entire life cycle of batteries.

A3M represents the French mining, metal industry, battery manufacturer and recyclers active in the whole battery value chain. We broadly support the European Commission’s ambition to develop a more sustainable battery market. The proposal for a regulation covers many of the key points:Eco-design, responsible sourcing, traceability and recycling, etc.

Filed in French · English published by the European Commission

Infineon Technologies welcomes the EU approach to minimize batteries’ harmful effects on the environment, covering the full life cycle from design and production, to reuse and recycling. As the leading provider of security solutions, one of Infineon’s key goals is to provide trust in a connected world.

EASE welcomes the proposal for the Batteries Regulation: although several criticalities are present, it is a step forward to tackle several of the barriers that currently hinder the battery market. First, EASE would like to underline that the current classifications and definitions, especially in the context of stationary storage, may need further clarification.

The German electrical and electronic industry organized in the association ZVEI believes that the proposed regulation for the battery sector published by the EU Commission on December 10, 2020 is a good approach to strengthen the European battery industry, to harmonize national regulations, and to take into account the increased sustainability requirements.

PowerShift welcomes the proposal put forward by the European Commission (EC) as a necessary first step to achieve a sustainable and extensive regulation for batteries, accumulators and waste batteries. At the same time, we see the need for improvement of the proposed regulation due to the impacts of raw materials used for batteries throughout their life cycle on human rights, the environment and global biodiversity.

Cefic representing the chemical industry sector in Europe welcomes the European Commission’s legislative proposal for a more comprehensive regulation on Batteries and its objectives including enabling the strengthening of the European production capacities with a common set of rules, contributing to fair and transparent trade/supply chains, enhancing innovation and standardization aspects in support of safety and…

EERA welcomes the European Commission approach of the transposition of the Batteries Directive into a Batteries Regulation. The fact that the Commission recognizes and addresses highly interlinked problems related to batteries is welcome to recyclers of waste electronic and electric equipment.

The ECOPILAS Foundation is a Collective Extended Producer Responsibility System (SCRAP) for the management of waste batteries and batteries. It was set up in 2000 by the main manufacturers and importers of batteries in Spain, thereby responding to the principle of producers’ co-responsibility for the management of waste from these products at the end of their shelf-life.

Filed in Spanish · English published by the European Commission

This feedback is provided by the National Research Council of Italy (CNR) on behalf of the Consortium of the H2020 project “CarE-Sevice-Circular Economy Business Models for innovative hybrid and electric mobility through advanced reuse and remanufacturing technologies and services” (Grant Agreement N. 776851).

I'm submitting this feedback in the role of the Coordinator of the H2020 DigiPrime project "DIGITAL PLATFORM FOR CIRCULAR ECONOMY IN CROSS-SECTORIAL SUSTAINABLE VALUE NETWORKS". DigiPrime develops a digital platform for supporting the development of cross-sectorial circular value-chains in Europe.

Orgalim, Europe’s Technology Industries, welcomes the opportunity provided by the European Commission to offer suggestions with regard to a new proposal for a Regulation for Batteries and Waste Batteries. Key messages from our industries on the new proposal for batteries, which are also relevant for any similar future legislative initiative considered within the new Sustainable Products Initiative are as follows: •…

GAHP is particularly concerned about the unsafe recycling of lead-acid batteries in LMICs and the informal smelting of the recovered lead plates, which is often the first stage of producing secondary lead material used domestically and/or exported for battery manufacturing or other uses.

The Cobalt Institute (CI) supports the Commission's broad objectives in this Regulation. We recognise the need to update existing regulations to keep pace with technological change and ensure the sustainable, long-term growth of the batteries industry in Europe. For further details on our position, please find attached full response.

The T&M Coalition was created in 2005 and represents an ad-hoc group of companies active in producing test & measurement industrial type products (Category 9 under RoHS). The Coalition members are leading companies in the sector including Agilent Technologies, Fluke Corporation, Keithley Instruments, Keysight Technologies, National Instruments, Tektronix and Thermo Fisher Scientific.

Motus-E welcomes the European Commission’s Regulation Proposal and fully supports the measures that aim to ensure a competitive, circular, sustainable and safe value chain for all batteries placed on the internal Union Market, overcoming the barriers to the functioning of recycling industry and the environmental problems related to the production, use and End-of-Life management of batteries.

A systemic European Circular Economy for traction batteries is crucial for achieving the desired economic, resource, and climate benefits expected from electric mobility. It is necessary to maximise the productivity of the materials used during the service life of the batteries and to guarantee safe recycling at the end of the service life.

Comments on the European Commission’s Proposal for a Regulation concerning batteries and waste batteries Summary and general remarks Vulcan Energy Resources welcomes the European Commission’s ambition to promote the development of a competitive, circular and sustainable value chain for batteries in Europe, and appreciates the huge effort that has gone into this legislative proposal.

Current regulatory measures and existing conditions do not sufficiently support the effective circular management of batteries and must therefore be modified. The EU Commission's draft for the revision of the EU Battery Directive represents a promising approach to support the circular economy for traction batteries.

APPLiA, the European association representing home appliances manufacturers, welcomes this proposal for a Regulation on batteries for a more coherent battery legislative framework while preserving the single market competition and innovation. Please find attached the industry's reaction with complementary comments.

Comments from the Association of Enterprises for Batteries, Batteries and Energy Storage — AMENDING THE PUBLICATION OF THE NEW BORRADOR REGULATION OF PILAS AND BATERIES. The Asociación Empresarial de Pilas, Batteries and Storage Systems, AEPIBAL, as an entity that encompasses the entire value chain in the battery, battery and energy storage sector in Spain, has drawn up this document with the comments and proposals…

Filed in Spanish · English published by the European Commission

The Association of Municipal Enterprises (VKU) welcomes the European Commission’s proposal to adapt the 2006 Batteries Directive to current circumstances and trends. This initiative to set sustainability requirements along the value chain will be a key element to pave the way for circular, sustainable and safe batteries of all kinds, in line with the Green Deal and the new Circular Economy Action Plan.

Filed in German · English published by the European Commission

The European Recycling Industries’ Confederation (EuRIC) welcomes the long-awaited proposed Batteries and Waste Batteries Regulation published by the EU Commission on December 10, 2020. It is a fact that improving the design of batteries – making them more sustainable, readily removable and easily recyclable - is a pre-condition to transition towards a circular economy.

Finnish Minerals Group wholeheartedly supports the ongoing effort to reform and especially harmonize the regulation on batteries and their recycling. However, there are some issues in the current proposal that FMG would like to highlight as potentially challenging or requiring clarification.

Dear Madam, Dear Sir, OceanCare welcomes the initiative of the European Commission to minimize batteries’ harmful effects on the environment and would like to seize to opportunity to provide some input to the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020.

As the European trade association for the light, electric vehicle sector, LEVA-EU welcomes the Commission’s proposal to include specific provisions for batteries for ‘light means of transport’ in the draft Regulation. However, if the current proposals are upheld, they will constitute no less than an existential threat to the European market of light, electric vehicles (LEV).

FER (Spanish Federation of Recovery and Recycling) welcomes this proposal of a new Battery Regulation. We attached our contibution. Our members are Non-hazardous and hazardous waste managers, waste carriers, Shredders, Post-Shredder/Media separation, Used Tyres treatment or Preparing for re-use/ Pallets.

Conc. Art. 59: We are pleased that independent operators will be granted access to the battery management system for industrial rechargeable batteries and electric vehicle storage batteries with a capacity of more than 2 kWh so that they can assess and determine its condition as well as the remaining lifetime.

The European Power Tool Association represents 26 manufacturing companies of professional electrical tools used by skilled tradesmen and DIY-customers for different applications such as construction site, automotive, wood working, painting, and cleaning. EPTA members are responsible for over 90% of power tools sold across Europe with an annual turnover of €7bn for professional tools and equipment.

Opinion of the Thuringia Ministry of the Environment, Energy and Nature Conservation (TMUEN) The Thuringia Ministry of the Environment, Energy and Nature Conservation (TMUEN) welcomes in principle the Commission’s proposal for a regulation on batteries.

Filed in German · English published by the European Commission

The German Association of the Automotive Industry (VDA) represents more than 600 companies in the automotive industry - manufacturers of motor vehicles and their engines, set-ups, installations, containers and vehicle parts and equipment - which produce in Germany. The automotive industry is the highest-turnover branch and generated a revenue of more than 435 billion euros in 2019.

The Battery Association of Japan, an industry association of Japanese primary and secondary battery manufacturers, submits the following comments on the document 2020/0353(COD) “Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020” published on December 10, 2020.

CONEBI represents the European Bicycle, Pedal Assist E-Bike, Parts & Accessories Industries via its 15 national industry members. In the EU there are about 900 companies providing more than 120,000 direct/indirect jobs. Via the CONEBI’s national industry members, more than 500 small, medium and large companies are represented in CONEBI.

The Japan Automobile Manufacturers Association (JAMA) is a nonprofit industry association comprising Japan’s fourteen manufacturers of passenger cars, trucks, buses and motorcycles. With climate change and other environmental issues being matters of global urgency, JAMA is committed to addressing relevant challenges in order to contribute to the European Union's policy objective of achieving climate neutrality by…

February 26 2021 Dear Sirs The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit organization with the character of a public-interest corporation. We welcome the opportunity to contribute the public consultation.

Dear Sir/Madam, please find attached the opinion of the Ministry of Environment, Energy, Food and Forestry in Mainz. (complimentary close) Ministry of the Environment, Energy, Food and Forestry (Rhineland-Palatinate in Germany)

Filed in German · English published by the European Commission

Circulor welcomes the EU Commission‘s approach and strongly supports the initiative to make ethical and responsible sourcing of raw materials at all stages of battery manufacturing requirement. In order to enable the re-use of batteries and compete with international market, companies in the EU need an increased data availability across industry participants to enable the second life of batteries.

Fortum welcomes the European Commission´s proposal COM(2020) 798 for a regulation concerning batteries and waste batteries, which sets minimum sustainability requirements for batteries in the entire value chain. Having a strong battery value chain is of strategic value and importance for Europe as well as for our industry.

Eucobat welcomes the Commission’s initiative to adapt and modernise the legal framework for the entire life cycle of batteries, which are one of the key enablers for sustainable development and green mobility, clean energy and climate neutrality, contributing to the Green Deal objectives.

“Climate neutrality by 2050” set the European Union as a target in the Green Deal. Batteries in particular play an important role here in the overall context. The steel industry also wants to contribute to the Green Deal: Through transformation of primary steel production, maximum use of secondary raw materials in production, innovation and evolution of steel grades — and an efficient circular economy.

Filed in German · English published by the European Commission

We congratulate the Commission on the elaboration of a comprehensive and detailed regulation of an important waste flow like batteries. The Voluntary Agreement on Lead-Acid Batteries Management is pleased to contribute to the regulatory framework on this topic. Please, find our feedback in the attachment.

Batteries are a priority topic for consumers. ANEC agrees with the Commission that considering and investing in the safety and sustainability of these products is crucial. ANEC supports setting sustainability and safety requirements for all batteries placed on the EU market.

Umicore welcomes the proposal for a European battery regulation. It contains many important elements that will improve the quality, sustainability, transparency and social responsibility of the battery value chain. In particular, we welcome the targets for responsible sourcing of raw materials, the embedded Carbon-footprint targets and the promotion of quality recycling.

Carbon performance labelling is a good thing. SMEs will certainly have to be informed about the maximum carbon footprint thresholds. Our suppliers usually source in China and/or Taiwan, where the main battery manufacturers are located. The consequences and implications of the delegated act in French legislation and its impact on our work should be clearly explained.

Filed in French · English published by the European Commission

L’exigence de la déclaration d’empreinte carbone pour les batteries rechargeables aura un impact modéré sur mon activité : elle nécessite de réaliser ces études avant la date prévue. L’étiquetage pour la performance carbone est peu utile puisque la méthode est connue et standard, et elle peut être contournée (cf Dieselgate).

Northvolt has read the European Commission proposal for a new Battery Regulation, COM(2020) 798/3, and sends this letter with response and comments to the text. In general, Northvolt welcomes the ambitious policy for establishing recycling requirements, policy to ensure carbon transparency towards consumers (carbon footprint) and requirements to ensure thorough due diligence processes on battery raw materials.

CEZ Group welcomes the initiative of the European Commission to revise the Batteries Directive and suggests to include the following in its Impact Assessment: Proposed policies should cover the entire value chain, starting with the secure supply of raw materials with special attention paid to local deposits of raw materials.

The Association of German Transport Companies (VDV), the trade association for over 600 public passenger transport and rail freight companies in Germany, welcomes the Commission’s initiative to update EU rules on batteries. In particular, in view of the increasing use of industrial batteries in electric vehicles, the promotion and recycling of environmentally friendly batteries plays a crucial role.

Filed in German · English published by the European Commission

Eurometaux represents European non-ferrous metals industry. Our sector is the key supplier and recycler of metals for portable, automotive and industrial batteries. The World Bank in 2017 projected that 1000% more metals will be needed for batteries on a global scale.

The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community which are users of industrial storage batteries and are positioned downstream of both production and manufacturing.

EU regulation on responsible sourcing of battery raw materials Background: The EU batteries regulation plans to: “Defining sustainability requirements for batteries to be placed on the EU market, including responsible sourcing of raw materials" [...] The EU Technical Report on Responsible Sourcing of Battery Raw Materials of 26th June 2020 stated: “Critically, there appears to be a significant disconnect between…

One of DEKRA’s main activities is carrying out vehicle periodic technical inspections (PTI). From this perspective, it would be helpful to establish a battery-identification-system. Importantly, such an identification system should be transparent and accessible in a standardised way.

We welcome the opportunity to contribute to the process of modernising the EU’s batteries legislation, to drive the development of a sustainable batteries value chain. For EGEC, a European sustainable batteries value chain must be first and foremost compliant with the imperatives of decarbonisation and those of minimising the environmental impacts. For this reason, EGEC acknowledges the emphasis put on recycling.

WEEE Ireland is a not for profit Compliance Scheme owned by its Members – Producers of electrical and electronic equipment (EEE) and batteries. The Scheme has operated under Ministerial approval since 2005 and is currently in its third approval programme 2017-2022.

We would like to thank you for the opportunity to comment and welcome the European Commission’s commitment to more sustainable batteries in the context of the “Modernisation of the EU Batteries Directive”. Responsible sourcing of raw materials, sustainable use of raw materials in battery production, reducting greenhouse gas emissions in the manufacturing process and improving the circulation of battery raw materials…

Filed in German · English published by the European Commission

AmCham EU supports the Commission’s ambition to ensure a competitive, circular, sustainable and safe value chain for all batteries on the EU market. Batteries have a critical role to play in supporting decarbonisation and the EU’s strategic industrial objectives. We consider work remains in aligning product policy with the waste framework and Waste Shipment Regulation.

• Orano thanks the European Commission for giving the opportunity to provide feedback on its Batteries roadmap and observes in the EU the positive move towards low-emission mobility through the support to gigafactories and the deployment of electric vehicles in Europe. • Orano is fully committed to contribute to the recovery Plan initiated by the European Commission by using its human and technological skills.

The Platform for Electromobility welcomes the batteries roadmap as a means to modernise the legislation regulating the sector. The European EV battery sector landscape has been developing at a rapid pace. Demand is to the point of outpacing volume, while research and innovation has led to rapidly evolving, innovative battery chemistries.

AVERE welcomes the opportunity to input on the Batteries Directive roadmap as there is a clear need to revise and update current legislation impacting the sustainability and competitiveness of the EV battery sector. The entire battery value chain represents a key industrial opportunity for Europe.

The Cobalt Institute (CI) supports the update of the current legislation on batteries, promoting the anticipated growth in the battery industry in the EU. This includes the overall benefits to transform the legal instrument into a Regulation, providing further harmonisation and certainty across the EU.

The ZVEI - German Electrical and Electronic Manufacturers´ Association appreciates the opportunity to comment on the European Commission’s inception impact assessment on modernizing the EU’s batteries legislation. We see this assessment as a further step on the way to a coherent legislative framework on batteries in Europe. Please find the feedback of the ZVEI in the document uploaded enclosed.

UFE welcomes the EC initiative to revise the Directive 2006/66/CE on batteries which will offer strong opportunities for a competitive, circular and sustainable value chain for batteries produced in Europe. UFE would like to emphasise the following points in the EC Roadmap.

Dutch Associations in waste and recycling fully support the ambition of the EU Commission and transition towards a green and sustainable and climate neutral future in which batteries play a significant role. Clean and sustainable energy is the way forward. However what we have missed in the plans and feedback thus far is the need for ‘design for safety’ next to eco-design.

The Global Alliance on Health and Pollution (GAHP) is an Swiss foundation and network of 60+ governments, UN and other international organisations, academia and civil society that promotes greater awareness of the fact that although pollution is responsible for 16% of deaths worldwide, almost entirely in low and middle income countries (LMICs), it receives relatively little policy attention and only a tiny fraction…

Batteries are becoming a priority topic for consumers. With the ever-reducing price of Lithium-ion batteries and technologies, we have the reality that batteries (integrated with solar/wind) could viably be powering the entire home as well as the car, the bicycle etc.

FEM represents European manufacturers of materials handling, lifting and storage equipment. Our members produce equipment that enables the movement, storage, control and protection of materials, goods and products. FEM welcomes the European Commission’s inception impact assessment on the modernisation of EU rules on batteries.

ECI response to the Inception Impact Assessment for the modernization of the EU batteries legislation The European Copper Institute welcomes the initiative of the European Commission to revise the Batteries Directive and suggests to include the following elements in its Impact Assessment: Recycling should be increased by achieving higher economic profitability through: • Reduction of recycling costs • Increase of…

At SUEZ, we fully support the European Commission's initiative to pave the way for a sustainable and competitive batteries value chain in the EU, whilst addressing the social, environmental and health impacts generated.

As the European Commission (EC) looks to modernize the EU’s batteries legislation, Amnesty International calls on the EC to ensure that human rights and environmental protection go hand-in-hand with the EU’s efforts to transition to green alternatives and address climate change.

Purpose of rules The Directive (2006/66/EC) has successfully delivered several of the intended objectives but references relating to the hazardous nature of mercury, lead and cadmium are outdated. They should be broadened to include critical raw materials, outlined in SWD (2018) 245. Cobalt, lithium, nickel, and graphite are important, finite global resources.

The Ecopilas Foundation is a Collective System of Extended Producer Responsibility (SCRAP) for the management of waste batteries in Spain. S U G G E S T I O N S FIRST. A change in the calculation method of the collection rate of waste batteries. ECOPILAS is proposing an alternative collection rate calculation method that reflects more realistically the quantity of waste portable batteries that can be collected.

The Austrian Chamber of Commerce expresses its gratitude for the opportunity to comment on the initiative “Modernisation of the EU rules on batteries”. • Concerning sustainability and competitiveness in the management of waste batteries is to be welcomed • The intended strengthening of secondary raw materials markets is also positive.

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Norsirk AS is a producer responsibility organization for batteries, electrical and electronic equipment and packaging in Norway. We organize the waste collection and recycling of these products on behalf of the producer, i.e. manufacturers, importers, and retailers. We embraced the initiative of modernising the “Battery Directive”.

EUROBAT welcomes the initiative of the European Commission on Modernising the EU’s batteries legislation: in the past years, EUROBAT remarked several times the need to adapt the legislative framework on batteries to take into account the increased importance of batteries to decarbonise our economy.

Lubin, 9 July 2020 ZPPM / 62 / VII / 2020 Employers Organization of Polish Copper position on modernising the EU’s batteries legislation Inception impact assessment (Batteries - modernising EU rules) Ref. Ares(2020)2777034 - 28/05/2020 Employers’ Organization of Polish Copper welcomes a European Green Deal to put Europe on the right track to a sustainable future and is prepared to take the necessary measures to make…

ACEA believes that any collection target would be inefficient to recycle more batteries. Therefore no changes are necessary to the actual legislation.Efficient and well-working collection and recycling processes, not only for automotive batteries and traction batteries, but for vehicles as such, are already implemented in many Member States.

Recser Oy, the authorized producer organization for batteries in Finland, welcomes the EU Commission approach to modernize the EU Battery legislation and would like to support the views of EUCOBAT regarding collection of waste batteries, extended producer responsibility and recycling as follows. • A change in the calculation method of the collection rate of waste batteries.

The Critical Raw Materials Alliance (CRM-A) represents primary producers, traders and associations of raw materials that the Commission has determined to be critical to the EU economy (CRMs). Several CRMs and their derivates are key components in batteries.

Batteries put on the EU’s single market must have robust sustainability requirements – we call for an ambitious set of rules regarding the sourcing of raw materials, design and manufacturing stages of batteries, and end of life, as well as the necessary information to be conveyed to end users and the supply chain actors, ensuring as follows: 1.

Alliance Renault Nissan welcomes the opportunity to comment on the IIA on modernizing the EU’s Battery legislation and support more circularity and sustainability. We strongly believe that batteries are essential for the transport decarbonisation and proper attention to its development is key for the future of our automotive industry. ELV Directive already apply to batteries used in cars.

MedTech Europe supports the European Commission’s commitment to ensure a competitive, circular, sustainable and safe value chain for all batteries placed on the EU market. Our submission focuses on the potential impact of a ban on primary batteries on the medical technology sector (medical devices and in vitro diagnostic medical devices (IVDs)).

Batteries are an essential product to ensure decarbonisation in the EU and its demand is set to grow substantially in the upcoming years. As an environmental civil society organisation, we strongly welcome the initiative of the European Commission to update the legislation that ensures a circular and sustainable value chain for all batteries produced in the EU and placed on the single market.

The Test & Measurement (T&M) Coalition and its specificities The T&M Coalition was created in 2005 and represents an ad-hoc group of companies active in producing test & measurement industrial type products (Category 9 under RoHS).

Eco-Bat Technologies welcomes the EU Commission approach to modernise the EU Battery legislation. Batteries are key enablers for the European Green Deal ambition for achieving a climate-neutral economy by 2050, and particularly the mobility and clean energy sectors’ transformation. Indeed, Batteries like Lead- Batteries play since decades an essential role in different applications such as e.g.

ECOBATTERIEN, the authorized compliance scheme endorsing the legal obligations of producers and importers of batteries in Luxembourg would like to highlight some difficulties faced by small Member States. We are conviced that the objective of the legal framework cannot be achieved on the basis of a regulation which seems to give more harmonisation at european level but which in fact makes it impossible to finance…

EGARA is the European association of car dismantlers. In this case we focus on traction batteries. A few items need special attention. Traction batteries are a class of their own. They are not just industrial batteries. They are used in vehicles used by mainly consumers or professional drivers on the road in cars, vans and even bigger commercial vehicles. Battery techniques change all the time.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) - Feedback on Batteries - modernising EU rules The promotion of environmental-friendly batteries in the fast growing EU market is of crucial importance for a sustainable development and resource management.

EPBA is the trade association representing manufacturers and importers of consumer batteries in Europe. Our member companies are committed to innovation and are constantly striving to offer enhanced quality and performing batteries that contribute to the transition to a more sustainable and circular economy.

Duracell welcomes the effort of the Commission of revising the current Battery Directive 2006/66/EC. It represents a great opportunity of preparing the European battery business for the future, while smartly protecting the environment. The Inception Impact Assessment has defined two topical blocks on how to improve A) Battery Environmental Sustainability and B) Battery Collection.

In order to modernise EU rules on batteries, we recommend the following measures be integrated in the legislation: A) Introducing a strong carbon criterion in the batteries legislative framework Batteries are an essential part of the development of low-carbon mobility in the EU but if the production and use of batteries result in a high level of CO2 emissions, their entire purpose is defeated.

EGMF members produce a very wide variety of equipment covering a large range of products, in terms of size and usage, for landscaping, forestry, turf maintenance and food production. Within our product portfolio, a wide range of products are battery operated, such as hedge trimmers, leaf blowers, brush cutters, chainsaws, shrub shears, robotic and walk-behind mowers and golf carts.

Electric mobility has a significant role to play in decarbonising individual transport, provided that certain constraints are properly addressed and anticipated. The carbon footprint of battery manufacturing depends mainly on the carbon intensity of electricity and the size of production. The higher the latter, the lower the carbon intensity of a battery production site.

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The new regulatory framework should address the current market needs in order to ensure an efficient batteries’ life cycle management, both from an environmental and economic point of view. From this perspective and as highlighted during the consultation activities, here is what we recommend regarding: extended producer responsibility for second-life, battery recycling, battery design and manufacturing.

Iberdrola is glad to provide feedback to this consultation sharing with the Commission and views on the critical importance of setting a forward looking framework on sustainable batteries based on their exponential growth as a driver for climate neutrality (notably in electrification of transport as shown is chart attached).

Stichting Batterijen is the representative of the Dutch producers and importers of batteries. In the Netherlands they are members of Stichting Batterijen, which finances the execution of collection and recycling by Stichting Stibat Services and develops a long term strategy to comply with regulations. Please find enclosed our feedback

The Union des Transports Publics et Ferroviaires (UTP), as a professional organisation of public transport undertakings in France, represents almost 170 urban transport companies in France. Some are linked to transport groups such as Keolis, Movica, the RATP group, SNCF Proximités, Vecalia France, Transdev and others are independent and can therefore also join the AGIR association.

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The Finnish Chemical Industry Federation has established a specified Battery Group, which consists of key companies in the battery value chain, from mining of valuable battery metals to the recycling of batteries. We welcome the possibility to give our input to the Roadmap consultation "Modernising the EU's Batteries legislation".

Finnish Steel and Metal Producers (FSMP) welcomes the opportunity to input on the Batteries Directive roadmap as there is a clear need to revise and update current legislation impacting the sustainability and competitiveness of the EV battery sector. The entire battery value chain represents a key industrial opportunity for Europe.

Sustainable batteries are a key element of the Commission’s plans to improve the competitiveness of strategic value chains, and decarbonise the EU economy to achieve climate neutrality by 2050. Their use will support the electrification of public transport which will have clear benefits in terms of reduction of CO2, improving urban air quality and potential for storing renewable energy.

The European Carbon and Graphite Association (ECGA) is the representative association of EU carbon and graphite producers, including the EU based graphite electrode producers going into Europe’s steel and foundry industry, electrodes and cathodes for the aluminium and ferroalloy industry as well as a wide variety of specialty graphite and carbon products for applications ranging from electric motors to modern…

Battery Association of Japan Feedback on Modernising the EU’s batteries legislation An EU single regulation for sustainable batteries will be a valuable tool to reduce the adverse environmental impact of batteries throughout the supply chain.

Dear Members of DG ENV.Unit B3 – Waste Management & Secondary Materials Enel SpA, a multinational company in the energy sector highly appreciates the EC initiative to ensure a competitive, circular, sustainable, and safe value chain for all batteries placed on the Union market.

FIA Region I welcomes the opportunity to provide input to the Roadmap on the modernization of the EU’s batteries legislation. Our 103 Mobility clubs represent over 36 million members from across Europe, the Middle East and Africa. Our members provide roadside assistance, legal advice, insurance, and many other services to their members.

Bellona Response to the Batteries Roadmap Bellona welcomes the batteries roadmap as a way to improve the sustainability of batteries while still ensuring the competitiveness of the sector. Electrification is the best way to eliminate emissions from road transport; will play a role in the decarbonisation of ships and machinery; and is already contributing to addressing the challenge of energy storage; which means…

The IIA sets up good directions for the development of policies on batteries. It indicates the need for an ambitious regulatory framework proposal, capturing the largely improved environmental performance and social impacts such as responsible sourcing, while promoting the EU's competitiveness and ensuring long term sustainability, also in view of the EU post COVID-19 green recovery.

CLIA Europe would welcome a proposal by the European Commission to modernize the EU’s batteries legislation. Whereas the inception impact assessment understandably references road transport and vehicles, we would like to emphasize that the application of batteries is also an important element of the strategies further reducing emissions in the cruise sector.

Currently, the EU legislation forms an important foundation for the green energy vision for all Europeans. At InoBat, we are honored to be working in this space to address the role of EV battery innovation, stationary storage, and recycling from our European home in Slovakia.

DIGITALEUROPE appreciates the opportunity to comment on the inception IA. In the past, we have extensively commented on the ongoing revision of the Batteries Directive (Directive). The inception IA document remains vague on the relationship between the envisaged “new regulatory instrument” and the existing regulatory framework for batteries. Based on the public consultation for the eco-design prep.

JUUL Labs supports the European Commission’s goal to ensure a competitive, circular, sustainable and safe value chain for batteries placed on the EU market and welcome the opportunity to take part in this consultation. From the onset, we would like to stress that any legislative proposal resulting from this consultation should be mindful of the variety of batteries on the EU market.

The Annex contains the position of SPECTARIS e.V on the modernisation of EU battery legislation. SPECTARIS e.V. is the German industry association for optics, photonics, analysis and medical engineering, representing the interests of some 400 German high-tech companies, which are predominantly SMEs.

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That there is a need for a revised battery directive and new regulation to fully benefit from the potential of a growing battery industry is evident. Northvolt would like to underline a few points regarding the inception impact assessment in order to have the new regulation in place as timely and effectively as possible. The full feedback will be submitted as attached file.

FEAD welcomes the EU initiative of modernizing the EU rules on Batteries in line with the Green Deal and other sustainability-related policies like the new CEAP. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: • Update and harmonization of definitions It is…

European Recycling Platform (ERP) welcomes the European Commission’s plans to modernise the European Union’s batteries legislation in order to reflect latest market and technology developments, to address the lack of definitions, and to align it with the latest amendments to general waste legislation.

BEBAT is located both downstream of the production and consumption, and upstream of the processing of waste batteries. Drawing on lessons learned from this operational position in the value chain, we welcome the Commission’s initiative to modernise the EU’s batteries legislation and we are calling for the modification of several key provisions of the current "Batteries Directive”.

Lithium-ion batteries will be the backbone of the economy’s decarbonisation, notably the EU transport. Unlike combustion engines that burn oil and release harmful emissions, batteries can be reused and recycled at the end of their lives. Batteries are the best technology we have today to make our road transport emissions-free.

The actual effort for supporting the fabrication of Li-ion cell in EU is making sense from economical and resources aspects only if a proper waste management plan is set. In their study, Gaines et al. (“key issues for Li-ion battery recycling” MRS Energy & Sustainability: A review journal p1-14, 2018) estimated that, with a proper recycling protocol and different policies, it would be possible to answer to the full…

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…

EPTA position on the EU’s Initiative “Modernizing the EU’s battery legislation” Market & Product Characteristics • The market has been constantly growing for the last years showing different growth rates between corded (2 – 3 % p.a.) and cordless (5 – 10 % p.a.). • The most popular groups of power tools already have detachable batteries.

To achieve the European Green Deal, a 90% reduction in transport emissions is needed by 2050 (compared to 1990) and road transport will have to move to zero emissions beyond 2025 which will only become possible with a massive uptake of battery electric vehicles. Therefore, success in the European EV revolution is heavily dependent on the success of Europe’s up and coming battery industry.

STIBAT is located both downstream of the production and consumption, and upstream of the processing of waste batteries. Drawing on lessons learned from this operational position in the value chain, we welcome the Commission’s initiative to modernise the EU’s batteries legislation and we are calling for the modification of key provisions of the current "Batteries Directive”. Attached is a document with out feedback.

EUCOBAT and its members are located both downstream of the production and consumption, and upstream of the processing of waste batteries. Drawing on lessons learned from this operational position in the value chain, we welcome the Commission’s initiative to modernise the EU’s batteries legislation and we are calling for the modification of several key provisions of the current "Batteries Directive”.

The proposed solution is the support to protect the electronic coordinating party and the discharge by shielding from electromagnetic interference with complete Ip and EMC seals in broad fields up to 30 GHz See www.solianiemc.com

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