Position paper – EU Batteries Regulation: main automotive priorities

The European Automobile Manufacturers’ Association (ACEA) fully supports the goal of reaching carbon-neutral road transport by 2050. From a regulatory point of view, the proposed EU Batteries Regulation will play a major role in the decarbonisation of motor vehicles.

However, as this position paper makes clear, ACEA believes that the current proposal features several unintended shortcomings that risk obstructing the innovation potential of European auto makers, by significantly increasing the number of, and extending the scope of, requirements for batteries – the critical part of an electric vehicle.

This might result in a slowdown of the electrification process, which could in turn jeopardise the EU climate targets.

This increase and extension of requirements could also undermine the efforts currently underway to improve the affordability of electrified vehicles for European citizens, and, as a result, have the unintended consequence of preventing a fast renewal of the fleet with electric vehicles.

Key messages

  1. Batteries must become sustainable, high-performing and safe
  2. We welcome the European Commission’s acknowledgment that specific requirements must be revisited at the time of implementation to determine their adequacy
  3. The proposed Batteries Regulation should avoid burdensome double regulation
  4. There should be more flexibility to adequately prepare producers and supply chains
  5. The proposed Regulation should not hinder innovation as it would slow down the electrification process, thereby jeopardising the EU climate targets
  6. The producer needs to have the right to organise the waste management of his product

Key recommendations

  1. Ensure workable implementation
  2. Favour existing international regulations
  3. Develop a standardised test for state of health
  4. Efficiently use resources to promote circularity in any value chain
  5. Clarify roles and responsibilities of producers in extended producer responsibility (EPR)
  6. Consider other carbon footprint calculation methodologies
  7. Avoid double regulation on repurposing and remanufacturing requirements
  8. Revise information and reporting requirements
  9. Acknowledge ongoing work on due diligence
  10. Use consistent definitions for the collection of waste batteries
  11. Consider impact of green public procurement provisions
  12. Retain 2kWh threshold for electric vehicle batteries
  13. Revise the definition of automotive batteries


Reproduction of the content of this document is not permitted without the prior written consent of ACEA. Whenever reproduction is permitted, ACEA shall be referred to as source of the information. Quoting or referring to this document is permitted provided ACEA is referred to as the source of the information. 

Content type Publication
Vehicle types All vehicles
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