Interview with Amélie Pans, Platform chair 2022

Interview with
Amélie Pans, 2022 chair of the Platform

WG Leaders will make sure to come up with excellent workplan for 2022, but beside the content, what do you think the Platform should focus on in 2022?  

The number of files relevant to the Platform keeps growing but our days weirdly are still 24-hours long. So I would recommend to refocus on key files and ensure we have a strong impact of each of them. I do not have strong recommendations on which to put up the list but that can be discussed within WGs. Secondly, I’d like to look for the Platform to gain efficiency in our internal discussions, reduce the amount of exchanged emails and multiplication of versions of our draft papers. And finally, the Platform should communicate externally more effectively  

How could the Platform communicate more effectively as you say?  

2022 will be a fight for attention among stakeholders and associations like us to talk with policy makers and raise our issues in the public debate. We’ll have to join efforts to talk louder than others. We all spend a lot of time to come up with Platform’s positions, organize events and so on; we don’t do that to put the papers up on the shelf but to communicate them around. An easy step forward would be to share them on our personal social media for example.  

You mentioned the importance of a gender balance governance, it is true that women are still underrepresented in the whole transport industry. What do you want to say  

Although it is outside the scope of the Platform to advocate for gender balance policies, we should make sure to lead by example here. Even before I take the chairwomanship, I must say with Emilia, Claire, Marie-France, Chiara and Sarah leading our working groups and Julia being our vice-chair the Platform was always at the forefront of the fight. What can we do more? There are many of transport and energy female leaders at EU and global – how about a series of interview with them to shine a light and inspire others?  And we should also walk the talk by ensuring that panels at our own events are always balanced. 

Since its birth in 2015, the Platform has been growing covering more parts of the value chain. In which direction would you like to see the Platform grow in 2022? 

Beside growing its impact on social media, I think we should also think about contacting allies outside the box. For example, the Platform could go and meet the navigator providers (Waze, Google…) regarding the mapping of the charging stations. We can also get in relation with builder associations when it comes to the EPBD to show them the added value of the charging infrastructures. 

By the way, I’d like to take some times to meet with members to discuss all those points and more during informal chat. You can plan a meeting here. 


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Our recommendations on due diligence initiative for a sustainable transition to electric mobility.

Due Diligence
for a sustainable transition to electromobility

The Platform for electromobility advocates for a sustainable mobility approach that protects the environment and human rights. To achieve this, coherence between legislative files will be key. The following steps should be taken on the Battery Regulation and the upcoming horizontal initiative on mandatory Human Rights and Environmental Due Diligence (mHREDD), while bearing in mind the difficulties encountered in implementing similar legislation, as was seen with the Conflict Minerals Regulation (CMR).

Strengthen and mirror the Battery Regulation’s provisions on due diligence

The Platform strongly supports the introduction of binding corporate responsibility rules within the Battery Regulation for due diligence throughout the battery supply chain. As this Regulation is likely to act as a framework for regulating other complex products arising from the mobility industries, the Platform therefore invites the Commission to strengthen the due diligence requirements.

Europe’s new level of ambition for due diligence on batteries should be mirrored in any upcoming legislation that impacts other transportation industrial sectors and their supply chains. Both zero emission and traditional combustion transportations should face equivalent strict requirements. Those common or equal obligations should cover the entire supply chain of an economic operator, including its business relationships and subsidiaries. Economic operators should have clear environmental responsibilities, addressing risks such as water contamination, air pollution, biodiversity. This should also be the case for human rights, addressing risks such as child labour, forced or unpaid labour and the freedom of association of workers and so on.

Horizontal initiative on mandatory Human Rights and Environmental Due Diligence (mHREDD)

The Platform supports the overall objective of the mHREDD Directive, as well as the opportunity to boost investment crucial for the electromobility transition: productions sites, innovation as well as employee retraining, upskilling and reskilling.

However, it is important the European Commission proposes an ambitious horizontal mHREDD, to match – at minimum – the Battery Regulation on the due diligence requirements included in Art. 39 and Annex X. If the due diligence requirements in the Battery Regulation are strengthened by the co-legislators – a step we are calling for – the gap between the new battery industries and traditional ICE producers would keep growing, undermining the growth potential of the former.

The mHREDD requirements should therefore be extended to those sectors that compete with electric transport. In particular, due diligence requirements must apply equally to the fossil fuel sector. This would provide consumers and authorities with full transparency on the diverse mobility options available on the market. In addition to the excessive complexity created by double standards, an unambitious mHREDD would not deliver the level playing field between competing industries, consequently slowing down the transition to electric mobility.

Companies falling within the scope of the mHREDD should be liable for human rights and environmental harm they – or a company they control or have the ability to control – have caused or contributed to. This range of control should be clearly defined.

On the impact on prices, costs may increase due to new requirements on suppliers. They will either adapt their production accordingly or will pull out of the EU market, thus restricting the sourcing possibilities for European manufacturers to more costly suppliers. Establishing ambitious environmental and social standards via supply chain due diligence rules will, however, enable batteries and vehicles manufacturers in the EU to compete globally on elements other than price alone.

Finally, implementation of the mHREDD should be harmonised throughout EU to avoid double standards and divergence between Member States. A Regulation is necessary to create unambiguous guidance for transnational companies on the methodologies. Any uncertainties – particularly on implementation, scope, certification and auditing – should be avoided.

Word of Warnings from the implementation of Conflict Minerals Regulation

Reflecting on the experience of the implementation of CMR – which legislates on a very specific set of minerals – is essential for ensuring the effective implementation of the horizontal mHREDD and of the Battery Regulation. We urge legislators to take all steps necessary to tackle the difficulties of implementing and enforcing all EU due diligence policies in all sectors, particularly for other critical materials for the transition of electromobility.

 Considering that the basic components of the CMR are taking a significant time to implement, the Platform is concerned by the feasibility for the European Commission to enforce Art. 39 of the Batteries Regulation and upcoming mHREDD. The Platform for electromobility underlines the following challenges to ensure provisions can genuinely be enforced. New measures should:

  • Address delays in recognising industry schemes, which are at the core of the CMR, without compromising a thorough auditing process of the applying scheme.
  • Rely on concrete outcomes rather than on reporting, as is the case for the CMR.
  • Ensure responsibility falls on the user placing the minerals on the market (i.e. OEMs in the case of transport industry), rather than on their Tier 1 or 2 suppliers, in order to get closer to the end users.