Critical Raw Materials Act: Our response to the EC's consultation.

Critical Raw Materials Act
Our feedbacks to the European Commission

The vital transition away from fossil fuels towards cleaner technologies for transport  will drive, depending on the technology, the demand for raw materials like lithium, nickel. Whilst some CRMs are available in the EU, Europe is largely dependent on third countries for mining, processing, refining and recycling, even more so in the case of batteries needed for EVs and considering the current geostrategic tensions. We would therefore strongly welcome a CRM package beginning of 2023 to tackle our three concerns:

With the e-mobility transition, the EU is lacking an EV value chain beyond battery manufacturing – i.e. extraction, refining, processing, and recycling, which today is located in third countries – and a coherent approach of using existing EU sources of battery materials.

Hurdles to permitting is due to a) the plurality of mining codes in Europe bringing different levels of ambition and lack of coherence across Member States. This leads to, in some cases, not having any safeguards in relation to social or environmental protection; b) lengthy permitting processes when multiple permits are required for both renewable energy production and sustainable mineral extraction projects; c) lack of expert capacity to ensure the efficient, robust and timely evaluation of Environmental Impact Assessments and Area Assessments.

Limited amounts of sustainably sourced materials, notably due to limited geological mapping of available resources. Barriers also exist to the reuse and repurposing of EV parts that could extend the lifecycle of CRMs before recycling.

Critical Raw Materials Act should therefore:

Include a single strategy on raw materials that defines expected needs, challenges, priorities and key lines of action with specific objectives of reducing the need of primary CRMs, with efficient reuse and recycle.

Assess the need of stockpiling mechanisms.

Provide financial, political support (e.g. tax reductions) to economic actors meeting the highest existing environmental and social standards. For EU-sourced material, the initiative would then work in relation with the package of environmental policies that control impacts from its domestic mining and refining operations and the high EU social standards.

Incentivise keeping valuable battery material in Europe, available for domestic recyclers, justifying their investments in EU today and incentivise the recycling of production scrap and blackmass/BAMM in EU.

Ensure the sustainability of CRMs by addressing adverse environmental and social impacts of their production or recycling. For imports, supply should come from responsible sources with robust certification, due diligence rules setting legal requirements for suppliers to control risk across their supply chains.

Support geological surveys to determine accessibility of domestic resources, including waste.

Mandate specific marking for any product containing CRMs to facilitate their recovery and recycling.

Streamline robust permitting processes without undermining existing environmental laws and in compliance of ESG criteria.

Support permitting authorities with additional expert capacities.

Digitalize permitting processes to ensure transparency and full engagement from project developers to local communities.

Support financially the development of recycling capacities as all recycling activities are not financially viable today due to the low cost of some primary resources. Support for the development of recycling capacities is indeed crucial to the circularity and sustainability aspect of CRM sourcing.

 Ensure consistency across different pieces of legislation – notably the proposed lithium salts classification – and make sense of the needs of the CRM demand sector.

Give the ERMAlliance the overall view of EU levers and make it a driving force behind the implementation of the strategy.


Encouraging sustainable materials to supply electro-mobility

Sustainable Products Initiative
Encouraging sustainable materials to supply electromobility

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With the de facto ban on sale of ICE vehicles voted earlier this year, the argument on switching vehicles to zero emission has won in Europe. There is widespread agreement and more importantly concrete policies and targets at the EU and Member State level setting the trajectories for this to happen.

However, for the EU to continue leading the way internationally, to ensure industry produces electric vehicles and supporting infrastructure (passenger cars but also heavy-duty vehicles, collective transport modes and upcoming innovative modes) that both enable the green transition and set the foundation for resilience in an uncertain future, a more holistic approach to sustainable transport and resource flows must be adopted. This should be done by incorporating in the zero-emissions tailpipe approach, another approach with circularity and other planetary boundary impacts from transportation life cycles.

With the Sustainable Product Initiative, the European Commission (EC) gave co-legislators the opportunity to reward more sustainable behaviours in manufacturing by linking incentives to sustainability of materials. The Parliament and the Council must therefore take the opportunity to put in place a supportive framework that incentivises future improvement of EV design and promotes circular value chains.

Innovations in battery technology and manufacturing as well as opportunities to reuse and recycle batteries and other high-value and impact components of electric vehicles (EVs) are already projected to significantly reduce greenhouse gas emissions over the lifetime of an electric vehicle: Transport & Environment have analysed EV life cycle CO2 emissions, finding that, on average, EVs are already three times cleaner than an ICE equivalent.[1] But while all vehicles on European roads will be zero emission, the policy framework will need to incentivise further innovations and improvements in recovery, recycling and re-using components and secondary raw materials.

To reach Europe’s 2050 climate objectives, it is necessary that all vehicles on the road are zero emission. But in addition, continuous improvement in sustainability beyond CO2 (reduction and prevention of impact to water use, biodiversity and other planetary boundaries from the materials chosen and processes undertaken) of vehicles is also vital. European legislation should therefore endeavour to support:

  • Innovations in materials, manufacturing and processes that improve both products and production processes sustainability.
  • Research and innovation in industrially co-generated materials, e.g., industrial by-products and residues, and materials generated from secondary sources to mitigate the use of natural resources and avoid unnecessary landfilling).
  • Advancement in the uptake of sustainably superior materials, e.g., recyclable composite materials and low- and carbon-neutral metals for vehicle body panels and parts.

We therefore call the EC to consider the following policy recommendations:

 

  1. Support the advancement of sustainable and circular products across the value chain, including investment into advanced ELV management focusing on harvesting parts for circulation, advanced disassembly for sorting and separation and recycling with the intention of closing resource loops within the EU.
  2. Focus on the precise sustainability performance of final products by providing a definition to differentiate the product from components and materials.
  3. Review the information requirements along the product supply chain between business-to-business (B2B) and business-to-consumers (B2C) products, components and materials.
  4. Pivot support schemes including incentives to take into account a lifecycle analysis (LCA) approach, going beyond just tailpipe emissions to include design, components, targets for low-carbon and carbon-neutral materials and production processes and systems for component and material value retention.
  5. Target incentives to the most sustainable vehicles – for example on the basis of their energy efficiency (km/kWh) and through life utilisation.

If the European Commission desires to continue to lead on sustainability and specifically circular economy topics we see the sustainable product initiative as a unique and well-timed opportunity to set the basis for significant advancement alongside Industry.

[1] T&E, ‘How Clean are Electric Cars?’, 2022.


[Video] Batteries are well placed to help Europe navigate the ‎current energy crisis

Batteries Regulation
Europe's main asset toward energy security

Batteries are necessary to fast forward electromobility, they store green energy, and can ensure critical infrastructure runs smoothly. In other words, batteries are critical to achieving the EU Green Deal objectives, and for the transition to renewables and electrification.

But the battery industry needs a fit for purpose policy framework to do so. In December 2020 the European Commission, proposed the new Batteries Regulation which is now being negotiated in trilogue.

It is key that the new Regulation enables a sustainable and competitive batteries value chain on our continent. The Regulation needs to introduce regulatory visibility for all players along the value chain on key aspects, including:

First, well-thought through timelines that would balance the need for a quick implementation of the ‎Regulation, whilst ensuring robust methodologies are developed.‎

Second, future potential restrictions of substances must take into consideration the impact onachieving strategic ‎autonomy for the EU battery sector, the performance of EV batteries, and the closed loop of the ‎substances needed for batteries.

And finally, correct definitions: of batteries as final products, and of the battery producer for Extended Producer Responsibility coherence. This will help establish a level playing field within and outside of the European Union.

We salute the Czech Presidency’s emphasis on promoting the EU energy security amid these uncertain times, and want to stress that batteries are naturally well placed to help Europe navigate the current energy crisis. We call for the Presidency to focus its attention on the Batteries Regulation


Let’s not let 40% of EV batteries go missing!

End-of-Life Vehicle Directive

On how the End-of-Life of Vehicles Directive revision can make the uptake of EVs faster and more sustainable.

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For Europe to become carbon neutral by 2050, road transport needs to be entirely decarbonised by this date. Considering the average retirement age of petrol and diesel vehicles in Europe (around 15 years), the Platform for Electromobility believes that an EU-wide phase-out date for sales of new pure internal combustion engine passenger cars and vans no later than 2035 is necessary to achieve this objective with a clear emissions reductions trajectory.

Last year, the sales of new BEV accounted for 5.3% of the total (1). In other words, European market will need to grow from 530.000 battery cars today to around 16 million in less than 15 years.

Considering that to produce the corresponding amount of battery cells will require huge quantity of critical raw materials. There are several critical raw materials for which these market requirements mean a significant challenge. For example, major manufacturers (2) have already announced they will not use Ni in their entry level models. On average, it takes 10 years from taking the internal decision to have a new mine in operation. Accelerating the recycling capacities is therefore key for the deployment of accessible and sustainable electric vehicles (LDVs and HDVs alike).

Yet, in 2014, 4.66 million end-of-life vehicles (ELV), representing 39% of the total vehicles being decommissioned, were at ‘unknown whereabouts’ (3). From 2007 at least, the ‘unknown whereabouts’ share has remained at a constant level4. The two main elements that explain most of the issue with ELVs at ‘unknown whereabouts’ are vehicle dismantling at illegal sites, and exporting of ELVs outside of Europe as used cars.

Consequently, it’s of key relevance for the deployment of electromobility and to reach 2030 and 2050 EU climate goals not to spoil 39% of used batteries from future EU battery ELVs. Reinserting those ELV into the recycling system will reduce the stress of primary production as well as cost impact and a potential slowdown of the BEV uptake by lack of affordable materials.

While it is true that vehicle registration procedures are the national competence of the Member States, each EU legal act has to comply with two fundamental principles laid down in the Treaty on European Union, proportionality and subsidiarity. The content and scope of EU action may not go beyond what is necessary to achieve the objectives of the Treaties. Also, given that transport is a shared competence, the EU may act only if — and in so far as — the objective of a proposed action cannot be sufficiently achieved by the EU countries, but could be better achieved at EU level.

As Member States have not been able to reduce since 2007 the number of ELVs at unknown whereabouts, the Platform for electromobility proposes to introduce the following dispositions in the revised ELVD:

  • Registering any road transport vehicle – including heavy-duty – when the owner is a resident (or registered company) in that Member State will have a large and cost effective impact on reducing the amount ‘unknown whereabouts’. By doing so, vehicle owners will face at least two payment obligations (i.e. insurance and Periodical Technical Inspection – PTI). Owners will therefore be incentivised financially to send the vehicle to an authorised treatment facility (ATF) when it reaches its end of life and therefore avoid those costs.
  • Provide necessary safeguards to avoid as much as possible temporary deregistration that currently causes loopholes and increase the amount of ‘unknown whereabouts’
  • In case of sale in the same Member State, or change of ownership (typically to its insurance company), the new owner will have to be updated in the vehicle registration system.
  • It will only be possible to deregister a vehicle under one of the following circumstances:
    • Destruction, after presenting a certification of destruction (CoD) issued by an ATF.
    • Export within the EU, after presenting the certificate of having been registered in the second Member State.
    • Export outside the EU, after presenting the customs declaration for export.
    • Theft, after presenting the police report. If the vehicle was recovered, the vehicle will beregistered again to its legitimate owner.
  • Additionally, it should be made compulsory to have a valid roadworthiness certificate for a vehicle to be exported outside EU as used car.

To achieve the ambitious but necessary objective of decarbonizing road transport by 2050, transport must be seen holistically and therefore all upcoming legislations should, like the End-of-Life of Vehicles Directive revision, should consider needs that a fast and sustainable uptake of electromobility requires.

  • 1 https://www.eafo.eu/vehicles-and-fleet/m1
  • 2 VW Power Day and Tesla Battery Day
  • 3 https://ec.europa.eu/environment/waste/elv/pdf/ELV_report.pdf. In the Assessment of the implementation of Directive 2000/53/EU on end-of-life vehicles, is defined the term “ vehicles of unknown whereabouts”: vehicles that are deregistered but without a Certificate of Destruction (CoD) issued or available to the authorities and also with no information available indicating that the vehicle has been treated in an Authorized Treatment Facility (ATF) or has been exported.
  • 4 http://ec.europa.eu/environment/waste/pdf/target_review/Final Report Ex-Post.pdf

Platform general comments for the trilogue negotiation on Battery Regulation

Battery Regulation
Our recommendations for trilogue

During current trilogue negotiation on the Battery Regulation between institutions, we welcome several changes introduced by the European Parliament (EP) and Council. Notably, we support:

✓ The change of scope for the carbon footprint declaration per battery model and plant, rather than per batch, as initially proposed by the Commission.
✓ In the EP text, ambitious deadlines for recycling and material recovery conditions for batteries on the European market whether they are imported or not.
✓ We welcome the emphasis on the waste hierarchy and the clarification on reuse of batteries when available on the market, notably the explicit transfer of Extended Producer Responsibility from producer to second user.
✓ Both texts base due diligence obligations on the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises, and that both EP and Council have strengthened the environmental risk categories in Annex X.
✓ The Grandfathering clause for spare parts proposed in the EP text.

We have however reservations and will remain vigilant on the following points:

Timeline & targets
The innovative approach of this regulation requiring multiple new sustainability criteria declaration and control, accompanied by close to 40 currently unknown secondary acts, is a first in terms of implementation.
Recommendation: ample resources should be dedicated by lawmakers to ensure that the proposed targets and timelines for the implementation of the new sustainability criteria can be met.

Guarantee of origins
Concerns over the explicit possibility in the Council text to use guarantees of origin alone as proof of clean and renewable energy for the purposes of the battery carbon footprint calculations.

Recycling and end of life
Binding recycling content should always go hand in hand with a careful assessment of the environmental costs and benefits, and compatible with the real technological state of the art and availability of recycled materials.
Further, availability of batteries for second life must be considered. We would like to stress that EV batteries should always be handled by professionals with a certain level of qualification, and that the same goes for potential EV battery waste. Minimum conditions for battery recycling outside Europe should be ensured, accompanied by a deadline for when such conditions must be established. This can help to get extra-EU battery recycling industry ready for incoming EOL battery volumes.
Recommendation: Recycling targets in Article 57, Annex XII must be brought forward in the Council text (in line with the timelines proposes by the Commission) to reflect the vital need for a domestic supply of raw materials. At the same time, the possibilities for reuse must be clarified as more EV batteries are available for second life.
The substances needed for EV batteries should always remain in a waste loop. Future potential restrictions of substances must take into consideration the strategic autonomy objective of the EU battery sector, the performance of EV batteries and the closed loop of the substances needed for batteries. In addition, second-life batteries should not be exempted from obligations on performances and durability.

Removability
We want to highlight the significant technical difficulties, safety and performance challenges coming with the EP’s proposed removability and replaceability requirements for EV and industrial batteries at cell level. Such requirements would remove any incentive or space to innovate and contradicts the idea of longer lasting and better performing batteries if battery pack designs are not allowed to change over time.
Recommendation: we do not support the extension of the removability and replaceability requirements to all batteries at cell level, as they would threaten the performance, safety, and technical integrity of the whole battery. We therefore call on maintaining the Commission’s current article 11 setting removability and replaceability requirements for portable batteries only.


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.


Platform’s feedback to the consultation Batteries – modernizing EU rules

The Platform welcomes the proposal for a Battery Regulation and strongly supports the need for modernisation of the existing batteries legislation. It must ensure harmonisation in the internal market and facilitate an accelerated shift to electrified mobility by engaging all parts of the battery supply chain. The regulation must establish proportional and well-designed provisions to enable sustainable battery production, use, and end-of-life management.

Generally, the timeline for the provisions should be well-thought through to ensure robust and harmonised application and enforcement. We need to strike a balance between the need for a quick implementation of the Regulation while ensuring a robust methodologies. Overall, the proposed measures shall promote cleaner, more competitive and more efficient battery manufacturing.

To avoid duplication or overlaps with existing legislation and requirements and limit excessive administrative burden on the nascent battery industry, the Platform sees a need to streamline and align provisions.

Read the PDF version here

While the Platform believes that the proposed requirement for carbon footprint declarations goes in a positive direction, we are concerned about the measure’s enforceability at the Member State level. Provisions should apply per battery model and manufacturing plant instead of “for each battery model and batch per manufacturing plant.” Rules on enforcement, methodology, and electricity accountability should also be clarified, to ensure:

1. Harmonised enforcement at Member State level and for imported batteries;

2. The use of representative data and supply-chain configurations to ensure comparability of declarations. E.g certification of energy use should reflect real world use of renewable energy and must not rely on purchase of green certificates (Guarantees of Origin).

3. The confidentiality of the declared primary data is respected.

The Platform strongly supports the introduction of rules for the responsible sourcing of raw materials for batteries. Similar due diligence requirements must also be applied as soon as possible to the fossil fuel sector as part of the upcoming horizontal due diligence legislation.

The Platform highlights that economic operators must have sufficient time to adapt to new data sharing requirements. The chosen method, be it battery passport or QR Code, should be streamlined with a focus on a single, innovative, and digital approach. The Commission must identify which data sets are essential to boost the data-sharing economy while ensuring confidentiality.

The Platform welcomes the Regulation’s intention to provide a regulatory framework for the transfer of liability and safety requirements for second-life EV batteries. The current provisions, however, require clarifications as regards access to BMS, conditions for the safe treatment of batteries, property rights protection, as well as ownership of data created by EVs. Moreover, the waste status of batteries is vital: the collection of waste batteries potentially suitable for repurposing should be designed in such a way that a second life business model can develop without creating a free pass for illegal waste transport. In particular, a clear-cut transfer of extended producer responsibility is pivotal to avoiding the risk of illegal export.

On end-of-life management, we welcome the recognition of batteries within a circular economy. Also, the Batteries Regulation now better differentiates between battery chemistries. However, the future regulatory framework should be aligned and consistent with EC 1907/2006 (REACH). To work towards a level playing field, we propose including a deadline for the adoption of equivalent conditions criteria for export of waste batteries to third countries. Minimum recycling conditions outside Europe must be set, including environmental and social criteria.


Platform for Electromobility reaction to the revision of the European Batteries Directive

The Platform for Electromobility – representing 39 industrial, urban and environmental stakeholders from across Europe’s e-mobility value chain – welcomes the Commission’s long-awaited publication of their proposal for new European rules for batteries as presented today.

This comprehensive legislation will be key to ensuring batteries on the European market are both produced in a socially and environmentally sustainable manner, while at the same time, putting the EU firmly on track to meet to achieving its 2050 climate-neutrality and industrial leadership ambitions as set out by the Strategic Action Plan on Batteries. The revision of the current legislative framework has the potential to provide further regulatory support and clarity for the European battery manufacturing and recycling industries by establishing legislative measures capable of increasing the continent’s competitiveness in the booming e-mobility sector. Specifically, the the whole objective of the proposal should create the legal conditions and incentives for a domestic, competitive, high-quality battery market to emerge in Europe, with true business cases for battery end of life management and environmentally sound recycling, which can help accelerate the EU’s transition to zero emissions.

Batteries will underpin Europe’s drive to climate neutral economy and zero-emission transport. In this context, we urge policymakers to keep the following in mind as the Commission proposal is debated in the European Parliament and Council:
1. Ensure comprehensive due diligence requirements – from sourcing, to refining and manufacturing – are supported at EU level so that the battery industry can bring social and environmental value along the entire value chain;
2. Develop a robust EU carbon footprint methodology addressing all batteries chemistries and covering all key emission hotspots/phases;
3. Pave the way for an effective, net-value circular economy strategy capable of treating developing waste volumes and meeting the needs of a fast-paced, innovative industry such as e-mobility.
4. Avoid batteries are not lost once they hit the market via an improved (end-of-life) declaration system;
5. Provide a consistent regulatory framework for 2nd life options of EV batteries.

As EV sales begin to take off in Europe, the future success of the EU’s ability to remain competitive with the rest of the world will be heavily dependent on the ability to domestically develop batteries at larger scale in order to meet EV demand and help accelerate the transition to e-mobility. Only with clear rules and high standards can Europe fully reap the benefits of a home-grown battery industry, bringing economic value, jobs and long-term growth as a part of the e-mobility transition.

Jayson Dong, Chair of the Batteries Working Group in the Platform for Electromobility, added that “this piece of legislation will be key to supporting a thriving European e-mobility ecosystem. It will play a key role in delivering on the innovation, sustainability and competitiveness ambitions of the 2017 launched European Battery Alliance and working towards the EU’s Green Deal roadmap. The Platform for Electromobility looks forward to engaging with all relevant EU decisionmakers on this file and sharing our wealth of expertise to ensure the EU becomes a leader in the manufacturing of innovative and sustainable EV batteries.”

For more information about the Platform and our detailed position on the revision of the Batteries Directive, please find our paper on our website here.


Batteries will underpin Europe’s efforts to achieve a climate neutral economy and transport electrification. In the European Green Deal, the European Commission stated that a ‘90% reduction in transport emissions is needed by 2050 (compared to 1990)’ and that road transport needs to move to zero emissions beyond 2025 . In order to reach this objective, Europe will have to significantly increase the uptake of zero emission technologies, with a strong emphasis on battery electric vehicles.

This will require large amounts of batteries on the European market required to power the mass expected number of zero emission vehicles. Within this context, the Commission should therefore take stronger action and prioritise these zero emission technologies in the upcoming EU Industrial Strategy and the Circular Economy Action Plan planned for March 2020 to support the domestic production of sustainable batteries.

In preparation for the upcoming EU Battery Strategy expected for October 2020, the Commission must prioritise a circular economy approach when it comes to addressing the recycling of batteries. This includes ensuring the security of supply of raw materials, the reuse (where adequate) and recycling of batteries, as well as the high  environmental and social values in the manufacturing process as ways to promote a sustainable EU battery industry. Moreover, it will be extremely important to take note of the emerging new jobs related to the dismantling and recycling sector overall, as well as the processing and the reincorporation of used active materials within new batteries (i.e. when repurposing is economically proven to be better than recycling).

This is the only path to build a strong and competitive sustainable battery industry in Europe. Success in the European EV revolution is heavily  dependent on the success of Europe’s up and coming battery industry. Only with clear focus and political will, can Europe fully enhance the benefits of a home-grown industry, bringing economic value, jobs and growth as a part of the energy transition.