Position Paper
04 July 2022

EUROBAT feedback on proposal for a Directive amending the Industrial Emissions Directive

EUROBAT, the Association of European Automotive and Industrial Battery Manufacturers, thanks the Commission for the opportunity to comment on the proposal for a Directive revising Directive 2010/75/EU (Industrial Emissions Directive).
EUROBAT calls on policy-makers to ensure that the Sevilla process and the permitting regime under the Directive properly take cross-policy processes and wider societal and economic impacts into account, in particular the wider objectives of the EU Green Deal and its zero pollution action plan for water, air, and soil.

Batteries are critical to the fight to decarbonise our economy and thus tackle climate change and reduce air pollution. All battery technologies - lead, lithium, nickel and sodium-based batteries — are needed to support the decarbonization of the transport, energy, logistics, and telecommunications sectors. Europe must indeed take the lead in designing and building the most environmentally sustainable energy storage solutions and supporting the development of its battery industry.
EUROBAT thus opposes any changes to the legislation which would disproportionately lengthen the permitting process, reduce regulatory predictability and, therefore, drive relocation of production to non-EU countries and disincentivise investments in battery manufacturing in Europe.
EUROBAT objects to establishing the lower ends of the best available techniques-associated emissions limits (BAT-AELs) as a basis for setting emission limit values, and to setting binding environmental performance limits in permits. EUROBAT also raises concerns about certain elements of the environmental management system (EMS).

The extension of the scope of the Directive to large-scale lithium-ion battery manufacturing and to the extraction and treatment of metalliferous ores is rejected in favour of further consolidation of a Sevilla process centered on processes rather than sectors.
Conversely, EUROBAT supports the proposal’s emphasis on innovation, specifically the establishment of a new dedicated centre to support innovation (INCITE) which would collect and analyse information on innovative techniques and characterise their state-level of development.

The ambitious timeline for the review of existing BAT reference documents (BREFs) (2024-2027) is also welcomed.

Download the full position paper here