EUROBAT

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the European Commissions initiative to strengthen the circular economy and to reinforce the single market for waste and secondary raw materials through the proposed Circular Economy Act.

EUROBAT, the leading association of European automotive and industrial battery ‎manufacturers,‎ supports the EU Commission's Critical Raw Materials Act in their urgency of action to address the 2030 risk of raw materials bottlenecks for clean energy technologies.

The European automotive and industrial battery industry supports the proposal for a Critical Raw Materials Act to ensure a sustainable supply of raw materials in the EU. Europe relies heavily on batteries to decarbonise mobility, energy systems and other sectors.

EUROBAT welcomes the European Commission’s proposal for a Corporate Sustainable Due ‎Diligence Directive and confirms its full support for the harmonisation of human rights and ‎environmental due diligence obligations in the EU and abroad. In this sense, we are committed to ‎implementing the most sustainable pathway in order to achieve a climate-neutral European Union ‎by 2050.

EUROBAT welcomes the already-tabled Ecodesign for Sustainable Products Regulation and re-‎confirms its full support for the creation of a fully-decarbonised economy by 2050. It is important ‎to further optimise products and create a circular economy ecosystem through more efficient ‎common standards that will help to reach the environmental objectives.‎ We commend the replacement of the former Ecodesign Directive…

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, thanks the ‎Commission for the opportunity to comment on the proposal for a Directive revising Directive 2010/75/EU ‎‎(Industrial Emissions Directive).

Index 1 1. General overview 2 2. Definitions (Article 2) 6 3. Hazardous Substance Management (Articles 6, 71 and Annex I) 8 4. Carbon footprint (Article 7, Annex II) 9 5. Recycled content (Article 8) 15 6. Performance and durability (Articles 10, 16 and Annex IV) 20 7. Labelling and information requirements (Articles 13-14, 64-65, Annex VI-VII-XIII) 24 8. Supply chain due diligence policy (Article 39) 27 9.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROBAT welcomes the initiative of the European Commission on Modernising the EU’s batteries legislation: in the past years, EUROBAT remarked several times the need to adapt the legislative framework on batteries to take into account the increased importance of batteries to decarbonise our economy.

EUROBAT, the association of European Automotive and Industrial Batteries Manufacturers, welcomes the European Commissions Environmental Omnibus initiative as an important step toward simplifying environmental legislation, reducing unnecessary administrative burden and improving legal clarity, while maintaining a high level of environmental protection and supporting Europes industrial competitiveness.

As EUROBAT, we are disappointed with the incomplete alignment between the proposed Regulation on circularity requirements for vehicle design and on management and the new Batteries Regulation. We request that: 1. Restrictions of battery substances to be removed entirely from the scope of the proposed Regulation on circularity requirements for vehicle design and on management of end-of-life vehicles.

With this position paper, EUROBAT would like to provide its expert input on the Inception impact assessment on the End-of-Life Vehicles Directive. Timing: the proposal is severely delayed First of all, we regret that the proposal is considerably delayed compared to the own Commission legal obligation to “review the ELV Directive, by 31 December 2020, and to this end, shall submit a report to the European Parliament…

EUROBAT, the leading association of European automotive and industrial battery ‎manufacturers, welcomes the European Commissions Net Zero Industry Act. ‎ Batteries are a key component of the energy transition and the EU needs more batteries if it is ‎to achieve its ambitious 2030 and 2050 climate and energy targets.‎This proposals signal an increasing shift towards an interventionist industrial policy, an ‎attempt…

EUROBAT welcomes the Commission Inception Impact Assessments for a revision of Regulation (EC) ‎‎No 1907/2006 of the European Parliament and of the Council concerning the ‎Registration, Evaluation, ‎Authorisation and Restriction of Chemicals (REACH).‎ ‎All battery technologies use substances that have hazardous properties. For instance, lead, cobalt, ‎nickel and cadmium are commonly included in batteries.

EUROBAT welcomes the proposal on Waste Shipment Regulation published on 17 November 2021 by ‎the European Commission. It is of paramount importance for the EU internal market to have a ‎clear regulation that allows, clarifies and facilitates waste shipment inside, and outside of the EU, ‎given that certain environmental and socio-economic conditions are met.

EUROBAT very much welcomes the initiative to review the Waste Shipment Regulation. We believe that the Regulation needs to be better aligned to the principles of the circular economy, above all regarding the end-of-life management and recycling of spent batteries in low- and middle-income countries, which currently have sub-standard installations for these purposes.

EUROBAT, the Association of Manufacturers of Automotive and Industrial Batteries, welcomes the upcoming ‎adoption of a methodology for determining the carbon footprint of electric vehicle batteries. EUROBAT maintains its ‎support for the introduction of a carbon footprint declaration, performance classes and maximum thresholds to ‎promote green batteries made in Europe.

EUROBAT welcomes the opportunity to comment on the draft delegated act adopted pursuant to Article 8 of Regulation (EU) 2023/1542. We appreciate the Commission's work and note that the proposed methodology is broadly aligned with the principles discussed during the JRC consultation, particularly as regards mass-balance accounting and documentation-based traceability. EUROBATs comments are targeted and constructive.

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, welcomes the proposal revising the CMRD and the lowering of the occupational exposure limit (OEL) and biological limit value (BLV) for lead and its compounds. Since 2021, Germany enforces a 15 µgPb/dL BLV. Conversely, 11 Member States still implement the maximum 70 µgPb/dL authorised by the current version of the CMRD.

EUROBAT is the leading association for European automotive and industrial battery manufacturers, ‎covering all battery technologies, and has more than 50 members. The members and staff work ‎with all policymakers, industry stakeholders, NGOs and media to highlight the important role ‎batteries play for decarbonised mobility and energy systems as well as all other numerous ‎applications.‎ EUROBAT welcomes the call…

EUROBAT, the association for European automotive and industrial battery manufacturers, together with RECHARGE, the voice of the advanced rechargeable and lithium batteries value chain in Europe, and Eurometaux, the voice of non-ferrous metals producers and recyclers in Europe, would like to support to the European Commission proposal for a regulation (COM(2025)258) postponing the due diligence obligations under the…

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.