EdEn welcomes the Commission’s proposal for a Regulation on batteries and waste batteries. We believe this proposal is an important step in reducing the environmental footprint of batteries throughout their whole life-cycle.
In particular, the definition of carbon performance classes, associated with a maximum emission threshold appears to be an effective way of avoiding the placing on the market of non-sustainable batteries while making it possible to differentiate, among the batteries that can be placed on the market, the ones that have the lowest carbon footprint.
We believe however that some other provisions need to be further assessed in order to take into account existing legislation and the diversity of battery technologies and applications:
- Avoiding duplication of existing processes;
- Taking into account the specificities of each battery technology and application;
- Addressing availability issues and competition issues related to recycled content requirements;
- Measuring adequately the carbon footprint of electric vehicle batteries.
