The release of the latest thinking in October by the European Commission on the 2006 Battery Directive — a so-called Evaluation Roadmap — has prompted a lively response from EUROBAT, the association of European manufacturers of automotive and industrial batteries. This Roadmap is the first step of the European Commission in the review and, potentially, the revision of the Directive.

“Broadly we’ve welcomed the roadmap that the Commission has set out,” says Alfons Westgeest, executive director of the trade association. “But we’d like to underline points in our thinking that we consider particularly relevant at this time to have a strong and sustainable European battery manufacturing industry.”

EUROBAT’s first position statement was an acknowledgement that the EU battery market is a fast-paced, competitive sector and a positive contribution for the whole region.

That said, the association suggested that the Battery Directive “should be made fit for these fast-paced changes. Any revised legal text should be able to respond more quickly to any such new development. The objective must be to put in place a regulatory level-playing field for all battery technologies while, at the same time, ensuring business certainty for battery producers and all operators in the battery value chain.

“For the evaluation process this means that administrative principles (such as producer responsibility, financing or reporting requirements) should be designed in a way to guarantee stability for the market, while technical elements (such as addressing emerging battery technologies) should be flexible to satisfy the requirements of sustainable development.”

In essence EUROBAT is seeking to ensure that the evaluation process, undertaken by the European Commission, for making changes can be fast-tracked and would not have to go through the long, formal processes that some changes to directives require, which would ultimately not be desirable for both battery users and producers as well as EU consumers.

In its second point, EUROBAT sought to push forward the need for better labelling of lead versus lithium batteries — while at the same time emphasizing that lead batteries are almost 100% collected and recycled; a fact that needs to be remembered within the context of the ELV and REACH proposals.

“To further improve collection and recycling processes, and to guarantee the safety of these processes, we ask to include a reference in the Batteries Directive to the forthcoming IEC standard (IEC 62902) on labelling of batteries according to their chemistry.,” the association said.

“The objective of this suggestion is not to replace the current labelling of automotive and industrial batteries (‘crossed-out wheeled dust bin), but to add coloured background labels to facilitate collection, sorting and, ultimately, treatment of these batteries.”

The proposal is an increasingly important one given the way that lithium batteries entering the lead battery disposal chain can threaten health and safety.

The third point looks for better “legal and regulatory coherence with other pieces of EU legislation such as the End-of-Life Vehicles Directive, REACH and the like”. In essence, EUROBAT is pushing for the larger picture to be taken into account — and most importantly that the Batteries Directive is the Directive that gives the overview position.

EUROBAT said: “We deem it as essential to assess and improve the legal and regulatory coherence of the Batteries Directive with other pieces of EU legislation. The Batteries Directive should be the primary legislative instrument used to regulate environmental, health and safety aspects of battery manufacturing, use and waste.

“This means that the overlaps between the Batteries Directive, the REACH Regulation and the End-of-Life Vehicles Directive should be identified and addressed to ensure that the legislative framework impacting EU battery technologies is coherent and simplified.”

Westgeest said: “Fundamentally we believe that decisions about which battery chemistry to use for a given application should be left to the markets, meaning producers of batteries and those using them.

“Any decision to substitute one battery chemistry for another must first include consideration of required performance (as these products are often used as back-up equipment providing safety functionalities), the analysis of the environmental impact from cradle to grave along with a consideration of socio-economic aspects.”