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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.

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.

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.

The EU urgently needs a new and robust legislative framework on zero emission infrastructure to support the 33-44 million electric cars (battery and plug-in hybrid) expected on the road in 2030 to align with transport decarbonisation goals. Consumers should have access to the EU single market for chargers.

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.

Transport & Environment (T&E) welcomes the Commission’s (EC) proposal for a regulation on the deployment of alternative fuels infrastructure. In particular the change of the legislative instrument from directive to a regulation T&E considers an important step in the right direction. (detailed feedback in attachment).