A considerate approach is needed for the European Commission’s Batteries Regulation

When it comes to regulating batteries, a measured approach is needed.

In June 2020, the European Commission published an inception impact assessment on a proposal for a new regulation on batteries to replace the Batteries Directive. This proposal is expected to be published in November. As an industry we are pleased to have our own Batteries Directive, and we look forward to the upcoming Batteries Regulation. The industry currently supports EUROBAT’s position paper on Batteries Regulation which contains 10 key asks. In these key asks, we are asking for support for the production of all battery technologies in Europe as well as a coherent legislative framework on batteries.

We would like for this upcoming Battery Regulation to be the one and only source to define requirements on batteries. Requirements outlined in the End-of-life Vehicles Directive have resulted in overlaps with the Battery Directive and we believe that this future Batteries Regulation should be the only reference for all battery technologies.

I recently attended a European Forum for Manufacturing discussion and a key topic raised electromobility’s role in achieving the green deal. When implementing rules and recommendations in the Batteries Regulation, I would ask for the European Commission to consider the following.

All battery technologies are currently supporting the transition to e-mobility and will continue to do so. Electromobility is more than the traction battery of the vehicle. There are many other batteries to consider, these include the 3V portable battery in the key, the 12V battery that enables the on board supply of electricity and the stationary batteries that are used in the production, distribution and storage of electricity. Batteries have a role in the transition to become  carbon free by 2050, but they need to be regulated carefully.

Lead batteries will continue to be used in transport, and many other battery technologies have a lot to learn from the circular economy principles exhibited by lead batteries. Lead batteries are a role model for circular economy.

One of the measures we foresee in this BatteriesRegulation, is to define a minimum recycled content for electric vehicle and industrial batteries. Having minimum levels of recycled content in batteries might seem an appealing change in terms of environmental benefits. However, there will be barriers to obtaining environmental benefits if this proposal is properly implemented, for various reasons.

Battery markets are growing, and a growing market can’t be satisfied by recycled material, hence secondary materials may not be available if targets for recycled content are too ambitious. COVID-19 has recently outlined our dependency on the imports of critical raw materials.

Secondary materials also cannot be reliably distinguished from primary materials; it is, therefore, unclear how a target on recycled content could be tested and enforced, above all for batteries imported into the EU.

Moreover, recycled content results in the need to discuss closed-loop vs open-loop: a closed-loop system is not necessarily preferable to an open-loop system. Metals recovered from batteries are also used in other applications. Forcing them to be used to produce new batteries instead would distort the market and force other sectors to look elsewhere for their raw materials with zero net gains.

The target for recycled content cannot be placed on individual products; we will have to look on families of products. This also raised the question, how can policy makers test and enforce these standards?

Batteries Regulation will define criteria for the second life of batteries.  Second life is a tool that may have the potential to improve the environmental footprint of batteries, but we have to acknowledge that a minimum level of recycled content is in direct contradiction with the promotion of second life – we can either reuse the materials OR the battery, we cannot do both at the same time.

Electric vehicle batteries that have reached the end of their life are usually 10-12 years old, and it can therefore be expected that they were designed 15-18 years earlier. At this point in the future, the performance of current batteries is likely to have improved significantly over this period of time, and it would be a pity to see valuable materials stranded in underperforming second life equipment.

The lead battery has proven its reliability during the COVID-19 crisis and is key to economic recovery. The upcoming Battery Regulation would benefit from assessing these factors, and considering the above implications.

Read more from EUROBAT and its members at the  European Forum for Manufacturing:

• Dr Christian Rosenkranz, Clarios on why all electro chemistries have an important role in the reduction of greenhouse gas emissions
• Rene Schroeder, EUROBAT on why accelerated demand for today’s key battery technologies will drive market growth needed for Green Deal achievements by 2030

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