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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.

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.

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.

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.

MOTUS-E welcomes the initiative of the Commission to evaluate the Directive 2014/94/EU. We believe the current provisions fail to support the goals of establishing a common framework of measures to mitigate the environmental impact of transport, since many of the alternative fuels allowed in the present release emit CO2 and some of them are pure or derivate fossil fuels.

Motus-e strongly welcomes the European Commission’s Proposal for a Regulation and fully supports the measures that aim to deploy alternative fuels infrastructure as a necessary instrument to reduce emissions from the transport sector in the long term in the European Union.

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.

Due to the rapid development of the EV market, and the necessity of a legislation that encourages further expansion, MOTUS-E considers that the current AFI Directive does no longer set the adequate framework to accompany the expected growing uptake of EV in the coming years.

The Directive 2014/94/EU was adopted at a time when the market of alternative fuel vehicles was still an emerging market. In 2018, a major milestone was reached as Europe accounted for its first million electric vehicles on the road and the future market outlook is promising.