The proposal for a new EU Battery Regulation was released by the European Commission in December 2020. The new proposal stipulated that batteries placed on the EU market should become sustainable, high-performing and safe all along their entire life cycle. Above all, the proposal suggests that (e-bike) batteries should be designed as such that they facilitate the reuse, repair and recycling of batteries and the appliances in which they are integrated.

E-bikes need safe, high-quality batteries

With sales of e-bikes reaching 4.5 million units in Europe in 2020, the industry organisation, Confederation of the European Bicycle Industry (CONEBI), has been directly involved in the EU advocacy process to state the importance of safe and high-quality e-bike batteries for European consumers. This includes warning about the safety concerns involved with battery repair.

Writing in a position paper on E-Bike Battery Repair, CONEBI says, “Currently there is no sound technical framework for repairing or remanufacturing e-bike batteries which is aligned with the type approval of batteries and thus with well-defined parts requirements and product/production process quality, product responsibility and certification and transport safety aspects as well as safety testing of batteries. Lacking this framework, any kind of battery repairing or remanufacturing can lead to loss of type approval and also to uncontrolled, potentially unsafe situations during actual use.”

New is best – for now

CONEBI goes on to say that is “a good decision for the consumer to invest in a new, compatible, higher quality and more innovative e-bike battery at the end of the lifetime of the first battery, if available.” However, the industry association does not rule out the possibility of repairs in the future. “Increasing the lifetime of batteries is an ongoing development process in the whole battery/mobility industry as is the investigation into the development of certified processes that may make repairing e-bike batteries possible in the future.

Additionally, together with other 10 industry associations – including the Advanced Rechargeable & Lithium Batteries Association (RECHARGE), Home Appliance Europe (APPLiA) and the European Portable Battery Association (EPBA) – CONEBI is also calling for clear rules on battery replaceability within the framework of the new EU Batteries Regulation. The joint position paper can be found here.

Separate category for LEVs

Besides CONEBI, other trade associations are also citing their concerns about the new Battery Regulation proposal. One of those is the trade association LEVA-EU. “We welcome the separate category which has been created for batteries for light electric vehicles,” says Annick Roetynck of LEVA-EU. “We have put in a lot of effort. Initially the LEV batteries were categorised as portable batteries and electric car batteries, which was anything but a suitable solution. However, we do not yet know what conditions will apply to the category of LEV batteries and in that respect we are concerned these conditions will be so strict that it will be very difficult for LEV battery producers to comply.”

“LEV batteries have to be sustainable while recycling and reuse is very essential, but it should not be the case that the conditions are unfeasible and thus endanger the survival of the LEV battery manufacturers.

A potential threat?

“A shortage of LEV batteries could also threaten the future of LEV manufacturers,” warns Roetynck . “LEVs offer great potential to make transport more sustainable, as the DLR study LEV4Climate has shown. It should not be the case that people jeopardise this sustainability in order to be the best student in the class when it comes to batteries.”

“Because the LEV battery category was introduced into the legal text during the decision-making process, the European Commission did not carry out an impact assessment. LEVA-EU has asked them to do that impact assessment before introducing very strict requirements in order to enter into a dialogue with the LEV sector about how to make LEV batteries more sustainable and circular. So we are now anxiously awaiting the final text,” concludes Roetynck.