"Enhancing the Sustainability of Batteries: A Joint NGOs' Position Paper on the EU Battery Regulation Proposal", 16 March 2021

...in December 2020, the European Commission adopted a proposal for a Regulation on batteries and waste batteries (referred from hereon as ‘Battery Regulation’)...With its Strategic Action Plan for Batteries, the EU made clear in 2018 its ambition to be a global leader in sustainable battery production. The intention to apply new rules to the battery sector was listed as one of the main activities of the EU Circular Economy Action Plan, with the objective to solve most of the regulatory and standardisation obstacles for a truly sustainable European battery value chain...

...Although the proposed measures will bring a significant improvement to the current situation, several aspects remain a matter of concern. For example, proposals foresee recovery targets of 70% for lithium by 2030, but this threshold is far too low to enable a competitive and circular EV value chain...Furthermore, the proposed switch from a ‘Directive’ to a ‘Regulation’ is necessary for consistent implementation across all Member States, improving harmonisation and legal certainty. Having in mind the single market rules, it is obvious that the design requirements aimed at improving circularity and detoxification must be set at a high level across all Member States. However, it should be possible for more progressive Member States to introduce more demanding national laws for collection and recycling rates, and therefore to exceed targets that are set in the regulation if they are able to...

...In this position paper, environmental civil society organisations (Environmental Coalition on Standards, Transport & Environment, Deutsche Umwelthilfe and the European Environmental Bureau) go through the measures proposed by the European Commission and point out aspects that are either missing or should be improved...

[For example, this paper suggests improvements on issues of classification and definition, recycling, performance and durability requirements, and due diligence, amongst others]...