Regulatory Affairs Director
International Lead AssociationShare this on LinkedIn
The EU needs to be bold in recognising the importance of the EU-centric lead battery chain and rethinking its approach to regulating industry
As the EU seeks to support member states and boost chances of a speedy and sustainable economic recovery it must be bold in re-thinking and improving its approach to regulating industry.
The pandemic has forced policymakers to adjust their thinking on securing raw materials and shoring-up European supply chains to reduce the bloc’s reliance on uncertain and unreliable external factors.
In much the same way regulators must tear-up the old rule book and look again at how they can support rather than restrict European companies who make products such as batteries – one of the key foundation products critical to achieving green growth.
Advanced lead batteries – with raw materials sourced in Europe, manufactured in Europe and recycled in Europe – support everything from cars and trucks to data centres, mobile phone networks and hospital back-up power. Without them, many essential services such as those we have all relied on during the coronavirus crisis, would fail to function.
But by their very nature rechargeable batteries, whether lithium batteries in electric vehicles or lead batteries starting cars and powering forklift trucks, are made from a complex array of raw materials, including some that are hazardous to health. But the benefits of this amazing technology far outweigh the risks. As they are sealed articles, batteries present little risk to users from exposure to hazardous chemicals and their manufacturing and recycling takes place in Industrial workplaces operating under strict permits already covered by a wide range of EU occupational, safety and health (OSH) and environmental legislation.
Which is why we need a new intelligent approach to regulating chemicals used in battery production. Until now the EU REACH Regulation has been the blunt instrument used to target many of the metals necessary to produce rechargeable batteries. However, a coalition of more than 60 companies, formed as a Cross-Industry Initiative (CII) is calling on the EU to invoke better regulation principles that will support access to battery raw materials -achieving exactly the kind of secure autonomy policymakers want to achieve in the post virus world.
The organisations represented by the CII believe that REACH Candidate Listing and Authorisation – a process designed to ultimately ban use of chemicals in Europe – should not be used when potential risks from a substance is limited to the workplace and can be more effectively addressed by effective workplace-specific legislation without critically damaging EU value chains such as those necessary for battery production.
In a policy statement issued this month the CII called for the Commission to develop better guidance for the so called ‘Risk Management Option Analysis (RMOA) process’. RMOA is the tool used by Authorities to determine whether REACH Candidate Listing, Authorisation or Restriction should be used in preference to other legislative actions such as workplace occupational exposure limits. The CII argue that proper use of RMOA is critical for achieving a sustainable economic recovery by supporting the concept of a ‘one substance – one assessment’ process, clarifying the interface between the REACH and OSH legislation and helping improve the prioritisation of the most appropriate chemical risk management measures that will bring the European Green Deal’s health and environmental objectives to life.
Ultimately the CII’s call for tailor-made and targeted use of REACH Authorisation is a much more proportionate approach to chemical regulation, one which would continue to ensure that the environment and consumers are protected but would also help ensure Europe remains a centre of excellence for the manufacturing of products in demand.
The market for reliable rechargeable battery energy storage continues to soar, it would therefore be folly to attempt to ban the use of the very substances vital to their production. In Europe, advanced lead batteries are the flagship for the circular economy, with nearly all being collected when they come to the end of their useful life and converted into new battery raw materials by an efficient network of highly regulated recyclers.
More than 80 per cent of the contents of a new lead battery made in Europe originates from recycled waste, collected in Europe.
As European Vice President Maros Sefcovic himself told the Batteries Alliance recently – we need to secure raw materials and boost battery making in Europe. As we recover from the economic devastation created by the coronavirus outbreak, this has become more critical than ever. And the EU’s chemicals regulators need to think how they can support effective battery manufacturing in Europe, not hamper it.
Originally published on the ILA website.