EUROBAT Feedback on public consultation on the targeted revision of the REACH Regulation

EUROBAT welcomes the public consultation on the targeted revision of Regulation (EC) ‎No 1907/2006 of the European Parliament and of the Council concerning the ‎Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and supports the Commission in its efforts to protect consumers, vulnerable groups and workers from the most harmful chemicals.

EUROBAT acknowledges the Chemicals Strategy for Sustainability’s ambition in relation to safe products and non-toxic material cycles.

While all battery technologies rely on substances with intrinsic hazardous properties, the risks for workers and the environment are adequately controlled through enforcement of workplace and environmental legislation specifying strict permitting conditions for installations and occupational health and safety provisions.

Regarding risks to consumers and professional users, batteries are sealed articles designed to prevent the release of the incorporated substances during the use phase.

EUROBAT calls on policy-makers to consider the targeted revision of REACH in the wider context of the Chemicals Strategy for Sustainability, which recognises that chemicals, including metals, are the building blocks of low-carbon, zero pollution and energy- and resource-efficient technologies, materials and products.

In light of the Green Deal’s ambitious climate change and air pollution mitigation goals, proper attention needs to be paid to the key role played by batteries in supporting clean transport modes and enabling the decarbonisation of the EU’s electricity grid.

As an organisation representing downstream users of various chemicals, EUROBAT would like to make detailed comments as regards question 7 (registration of certain polymers), 8 (environmental footprint of substances), and 13 and 14 (Authorisation and Restriction).

EUROBAT is the leading association for European automotive and industrial battery manufacturers, covering all battery technologies, and has more than 50 members. The members and staff work with all policymakers, industry stakeholders, NGOs and media to highlight the important role batteries play for decarbonised mobility and energy systems as well as all other numerous applications