January 27, 2022: EUROBAT in January published concerns about the EU’s Batteries Directive, which could have one of the biggest impacts on the industry for decades.

In a paper jointly produced by a number of organizations in the battery industry, five key concerns were laid out for the European Parliament to consider.

One of the Battery Directive proposals is to require all EV, industrial and automotive batteries above 2kWh to use ‘minimum levels of secondary materials’ from 2030.

But as EUROBAT points out, there is no way of knowing now how many secondary raw materials will be available by 2030. At the moment very little lithium battery recycling is done, so unless that improves, the necessity to source secondary materials such as lithium ‘might cause production stops in the EU or force European manufacturers to source secondary raw materials producers from non-European producers’, EUROBAT says.

“It would disproportionally benefit the import of batteries from non-EU countries where higher volumes of waste from batteries and other products for the production of secondary raw material are available,” it says.

“Recycled content targets incentivise the premature end-of-life of batteries and are in direct opposition to long lifetimes and second life. Conversely, measures promoting re-use, remanufacturing and repurposing would extend the lifetime of the battery and delay their recycling, reducing the total amount of batteries available for recycling and hence decreasing the availability of secondary raw materials.”

The second concern raised is on design requirements, which EUROBAT says are too prescriptive and do not allow for evolving technological progress, including chemistry improvements – so while targets might be set, how they are achieved should be left to the market.

Other key points raised by EUROBAT include too stringent material recovery targets; superfluous hazardous substances restrictions (which would duplicate the existing REACH restrictions); and that a proposal to measure the carbon footprint of all batteries should be applied to specific battery chemistries rather than a ‘one size fits all’ policy.

“We believe that the battery sector is too important and strategic to make it a test case,” says the joint response. “All measures should be designed and implemented with an acknowledgement of the complexity involved in their delivery over the next decade.

“We call on co-legislators in the European Parliament and Council to consider fully the global battery market’s diversity and fast pace, and to only introduce new ambitions if their impacts have been fully assessed.”