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EU consultation

Sustainability requirements for batteries

20 submissions from 20 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission lists 205 submissions on this file. Shown here: the 20 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.

Who showed up

10 submissions from industry — companies and their trade associations — against 7 from civil society: NGOs, consumer organizations, environmental groups and trade unions.

Industry 10Civil society 7Public authorities, academia, other 3

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.

What the room declares

12 of 20
in the EU Register
119
full-time lobbying staff
€8.4M+
declared costs a year
84
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 8 Aug 2019 — it ran from 13 Jun 2019.

Policy area
Industry (DG GROW)
Where it stands
Awaiting adoption
Adoption expected
30 Sept 2019

How it got here

  1. Impact assess incep6 Feb 2019
  2. Public consultation8 Aug 2019

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Draft implementing regulation, Implementing regulation.

Showing 20 of 20 submissions.

O

Orange

· · filed 6 Feb 2019 · source

Orange is one of the world’s leading telecommunications operators with a total customer base of 261 million customers worldwide at 30 September 2018, including 201 million mobile customers and 20 million fixed broadband customers. Orange is present in 28 countries, including 7 Member States.

LinkedInX
CI

Cobalt Institute

· · filed 6 Feb 2019 · source

PDF

The Cobalt Institute (CI) is an international non-profit trade association composed of the major producers, users, recyclers, and traders of cobalt. The CI promotes the sustainable and responsible production and use of cobalt in all its forms.

LinkedInX
PF

Platform for Electro-mobility

· · filed 6 Feb 2019 · source

The Platform for Electromobility, representing 35 industry and other stakeholders committed to promoting e-mobility, welcomes the Commission consultation on Sustainable Batteries, and agrees with its main objective to produce safe and sustainable batteries with least environmental footprint.

LinkedInX
E

EUROBAT

· · filed 6 Feb 2019 · source

PDF

EUROBAT welcomes the work of the European Commission on sustainability of batteries. Producing green batteries in Europe is fundamental to fight climate change and ensure a just transition towards a decarbonized society offering jobs and growth for all Europeans.

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R

RREUSE

· · filed 6 Feb 2019 · source

PDF

Dear members of the European Commission, RREUSE, the network of European social economy enterprises active in re-use, repair and recycling, welcomes your commitment to take action towards an improvement of the sustainability requirements linked to batteries placed on the European market.

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E

Eurometaux

· · filed 6 Feb 2019 · source

PDF

Eurometaux, representing European non-ferrous metals producers and recyclers, supports the European Commission’s initiative to improve the sustainability, energy and environmental performance of batteries placed on the EU market. Our sector is actively involved in the EU’s Battery Alliance & Action Plan, sharing the objective to develop globally competitive value chains for batteries in Europe.

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BA

BEUC and ANEC

· · filed 6 Feb 2019 · source

We appreciate that the European Commission is looking into improving the sustainability, energy and environmental performance of batteries. Batteries are present in a large range of consumers products and will become increasingly relevant in the future given their use share in e.g. energy storage systems, and in electric vehicles. In this light, batteries are priority products for consumers organisations.

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IA

Impact Assessment Institute

· · filed 6 Feb 2019 · source

PDF

The Impact Assessment Institute is an impartial foundation that scrutinises the evidence put forward for EU policy and legislation. The Institute does not have a policy orientation and our feedback on the inception impact assessment (IIA) on Sustainability requirements for batteries is not submitted on behalf of any other organisation.

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NI

Nickel Institute

· · filed 6 Feb 2019 · source

PDF

The Nickel Institute as industry association representing the interests of nickel producers welcomes the European Commission´s inception impact assessment which was launched on 9th January 2019 as part of the better regulation agenda and the Strategic Action plan of the EC´s Batteries Alliance in view of sustainability requirements for batteries.

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TE

Transport & Environment

· · filed 6 Feb 2019 · source

The main objective should be to reduce the overall environmental footprint of the whole battery supply chain from the upstream materials sourcing to the downstream battery and car manufacturing. Only ethically sourced materials and sustainable battery manufacturing can underpin EU decarbonisation. Some downstream companies have already launched initiatives to improve mining standards and local benefit sharing, e.g.

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FF

Facing Finance e.V.

· · filed 6 Feb 2019 · source

We welcome the initiative to introduce responsible sourcing standards for the production of batteries, as the minerals used for battery production can have a significant impact on the communities and the environment they are sourced from.

LinkedInX

ECOS believes that at the EU should take action to reduce the environmental impact of batteries, using existing legislation and by introducing new legal instruments addressing all phases of the value chain, from (ethical) sourcing of raw materials to recovery. Regarding the policy options presented, ECOS considers that a combination of options 3, 4 and 5 would be appropriate.

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R

RECHARGE

· · filed 6 Feb 2019 · source

PDF

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.

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EC

European Copper Institute

· · filed 5 Feb 2019 · source

PDF

ECI welcomes the opportunity to provide input into the consultation on sustainable batteries. Considering the fast evolution of technology, policy needs to be forward-looking and agile to respond to new developments in this field. The EU is lagging behind other regions in terms of new battery technologies while often leading in regulation on environmental and social protection.

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PE

PowerShift e.V.

· · filed 5 Feb 2019 · source

We welcome the initiative of the European Commission and thank you for the opportunity to comment. Sustainable batteries are a key product of Europe’s energy and mobility transition. They must meet high climate, environmental, resource policy, human rights and social criteria and become part of the EU Circular Economy.

Filed in German · English published by the European Commission

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TP

TRAFIGURA PTE

· · filed 5 Feb 2019 · source

Trafigura supports the promotion of EU requirements for “sustainable batteries” and, more particularly, “the ethical sourcing of raw materials for the production of batteries”. Trafigura supports in particular ‘Option 5’ in the EU roadmap and welcomes further efforts to ensure ethical sourcing of raw materials for the production of batteries.

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EA

European Automobile Manufacturers Association (ACEA)

· · filed 5 Feb 2019 · source

ACEA acknowledges the Commission’s efforts to establish an innovative and competitive European battery value chain and to foster safe and efficient development and use, together with high sustainability requirements for batteries placed on the EU market.

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S

Svemin

· · filed 5 Feb 2019 · source

On behalf of the Swedish Association of mines, mineral and metal proudcers, SVEMIN, we would like to address following: Svemin - Welcomes the initative from the Commission regarding sustainability requirements for batteries and the ambition to improve the sustainability, energy and environmental performance of batteries placed on the EU’s internal market.

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EE

EURAMET eV

· · filed 2 Feb 2019 · source

EURAMET welcomes this initiative. A part of it aims to extend “… the useful lifetime of the batteries with second life applications”. We support activities on the European level to reuse batteries salvaged from electric vehicles, since they can still be used for many years afterwards.

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JS

JFMO SERVICIOS EN INTERMEDIACIÓN PÚBLICA

· · filed 22 Jan 2019 · source

Sustainable development must be a priority in the global context, especially in clean and renewable energies. Europe needs to establish leadership in implementing policies targeted at the 17 Sustainable Development Goals. The development of sustainable batteries is a major step forward in the global context.

Filed in Spanish · English published by the European Commission

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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.