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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.

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.

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.

Northvolt welcomes the European Commissions carbon footprint methodology for batteries for electric vehicles in its current form, as a balanced compromise between different policy considerations. It is important and urgent to have a framework set in the immediate term, both for the sake of regulatory certainty for industry and for the sake of transparency on the carbon intensity of production to ensure a sustainable…

DUH welcomes the Commissions draft act on the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. The most energy- and carbon-intensive part of battery manufacturing is the production chain of battery cells, responsible for as much as 75% of energy consumption.