Decisive negotiations on batteries: NGOs demand clear commitments to responsible sourcing, design, reuse and recycling

ECOS – Environmental Coalition on Standards, European Environmental Bureau (EEB), Transport & Environment (T&E) and Deutsche Umwelthilfe (DUH) call on the European Commission, Parliament and Council to agree on ambitious environmental targets in the trialogue negotiations starting on April 20th.

Four of the largest environmental organisations in Europe call on negotiators to introduce an environmentally ambitious legislative framework for batteries, particularly with regard to due diligence, low carbon footprint, collection of used batteries, establishment of a deposit system, replaceability requirements, high quality recycling, prevention of illegal imports and promotion of second life applications.

After the European Parliament and the Council submitted their final amendments to the Commission’s proposal for a Batteries Regulation, decisive negotiations among the three institutions are kicking off tomorrow.

Ahead of the trialogues, NGOs provide negotiators with an overview of civil society recommendations on each institution´s position to ensure a truly sustainable battery market in the EU. [1]

Notably, NGOs warn that requirements risk to be dramatically weakened during the course of the negotiations, especially as some proposals do not cover all battery types or foresee delays of several years before they enter into force.

With electromobility and digitalisation booming, the EU Batteries Regulation is crucial to guarantee sustainability requirements for the whole life-cycle of batteries, from ethical mining of raw-materials to their end-of-life. The final outcome of this Regulation will be an important blueprint for other future legislative initiatives, such as ecodesign requirements for sustainable products and collection and treatment rules for waste electrical appliances.

Rita Tedesco, Senior Programme Manager at ECOS – Environmental Coalition on Standards, said: “We are at a turning point for battery production. In Europe alone, at least 38 battery gigafactories are planned or have been announced, with enough capacity to power around 8 million electric cars. The final result of the trialogues will determine whether the battery boom will be truly sustainable. Weak rules could result in tonnes of additional waste, and make Europe dependent on a handful of countries for the sourcing of rare materials, such as nickel, cobalt and lithium. For batteries to sustainably power the energy transition, regulations must enable batteries to have long lifetimes, be easily repaired when they break, and, at the end of the road, be repurposed for a second life”.

Jean-Pierre Schweitzer, Senior Policy Officer for Circular Economy and Product Policy at the EEB, said: “Europe relies on imported resources to produce batteries, so it must lead on high environmental standards and its ambition for a circular economy. It is crucial to make reuse, repair, refurbishment and high quality recycling the default option for all batteries. Going into the negotiations, the Parliament’s position is our best bet to minimise the risks of future dependencies”.

Alex Keynes, Clean vehicles manager at Transport & Environment, said: “Amendments adopted by the European Parliament put Europe firmly on the path to a sustainable zero-emissions future and ensure that electric vehicles and light means of transport will continue to improve their climate advantage over combustion engine equivalents. With regard to battery recycling targets, it is essential that policy makers prevent current proposals from the Council delaying the recovery of secondary raw materials. Europe’s battery factories are being set up today, and industry cannot wait until 2029 to start building up a domestic supply of critical metals like Lithium”.

Thomas Fischer, Head of Circular Economy at Environmental Action Germany (Deutsche Umwelthilfe – DUH), said: “The collection of old batteries is a necessary prerequisite for reuse and recycling. If portable batteries end up as household waste, valuable resources are lost completely and there is a higher risk of fires in treatment plants. Therefore, return incentives, high collection targets and consumer-friendly take-back options are essential to guarantee proper treatment for all batteries. A highly effective solution to guarantee high collection would be a deposit system for Lithium-Ion batteries. Unfortunately, the current proposals delay the setup of such a system for many years. Another crucial point within trialogue negotiations may be the undermining of battery regulations by non-EU sellers through online marketplaces. The Council proposed effective measures against illegal imports, which must not be weakened under any circumstances”.


[1] Decision aid for negotiators giving an overview of current proposals from EU Commission, EU Parliament and EU Council as well as presenting NGOs joint positions on decisive topics for sustainability during battery life-cycle:

[2] Environment Council, 17 March 2022 – Fit for 55 package:

[3] Transport & Environment brief – Weak climate rules put Europe’s battery boom at risk:

[4] New rules on batteries: MEPs want more environmental and social ambition:

[5] McKinsey & Company – Recharging economies: The EV-battery manufacturing outlook for Europe:

Decisive negotiations on batteries: NGOs demand clear commitments to responsible sourcing, design, reuse and recycling
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