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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.

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.

The current directive fails to mitigate the environmental impact of transport, since many of the alternative fuels currently allowed emit CO2 since some of them are pure or derivate fossil fuels. The current directive does not set the adequate framework to achieve long-term EU CO2 emissions reduction objective, as it does not adequately support the deployment of zero emission mobility.

As the pioneer and global leader in zero-emission electric vehicles, the Alliance Renault-Nissan welcomes the revision of the Directive 2014/94/EU. It supports and recognizes the priorities flagged by the European Commission for this Initial Impact Assessment. It agrees the primary problem is an insufficient amount and coverage of charging stations.

The ‘Fit for 55’ package paves the way for the implementation of the EU Green Deal, this set of legislative revisions represents a unique opportunity for Europe to take a step forward and win the climate race. That is why now it is the time to show steadfast commitment and prioritize the most efficient, sustainable and cost-effective pathways to decarbonize the economy.