ECHA should drop plans for ‘disproportionate’ regulation of lead metal - a key battery raw material supporting Europe’s Green Deal objectives

ECHA is recommending that lead is added to the REACH ‘authorisation list’¹. This regulatory move would signal an expectation of regulators that the substance would eventually be substituted and in the meantime could only be used through granting of specific, time-limited permission from the EU Commission.

Approximately €2 billion worth of lead from recycled sources is used per year for EU lead battery production so this threat won’t only impact Europe’s lead producers – battery manufacturers all the way though to metal recyclers will face more bureaucracy, risking jobs and investment. The move could damage several essential sectors including those producing innovative energy storage solutions and involved in delivering a circular economy in recycled metals and materials.

The EU’s lead battery value chain is proven and economically sustaining; other impacted industries using lead are just as important to supporting Green Deal objectives. These include those making the cables for renewable energy which link our wind farms to the grid, solar panel manufacturers as well as Europe’s world-leading metals recycling industry.

A metal used to manufacture millions of batteries critical for everything from hybrid and electric vehicles to renewables energy storage is simply too critical to face this disproportionate regulation – particularly where the Batteries Regulation is already set to strengthen the existing legislative pressure for substitution and complement the time-limited exemptions for lead under the ELV Directive.

Lead batteries are one of the true examples in the EU of a truly circular economy where waste is converted, locally, into valuable new products, limiting the need to extract raw materials from the earth or reliance on imports, whilst supporting thousands of high-quality EU jobs.

This sustainable and globally competitive success story, one that has tangible benefits not just to the EU’s political objectives and its economy, needs to be better recognised by policy makers. In a position paper our industry highlights that the lead value chain is already one of the most highly regulated industries in Europe, with some of the world’s most stringent rules protecting health and the environment that have already resulted in substitution where alternatives that meet end-users’ technical needs exist.

On this year’s EU Industry Day we call on regulators to halt the plans and consider this existing world-leading value chain’s contribution to the Green Deal and Europe’s low carbon future.

1. REACH – Regulation of the European Union about the Registration, Evaluation, Authorisation and Restriction of Chemicals