The lead battery industry has urged the European Commission to use its discretion to grant an Article 58(2) exemption from REACH authorisation for use of lead compounds in battery manufacturing.
Four lead compounds - lead monoxide, lead tetroxide, pentalead tetraoxide sulphate and tetralead trioxide sulphate have been proposed for inclusion on the REACH 7th priority list. The European industry, including EUROBAT, the International Lead Association and supply and value-chain partners has pointed out that all four compounds are essential and irreplaceable in the manufacture of lead-based batteries with no substitutes available.
In its statement the industry also said: "Substitution would also significantly undermine the competitiveness of the European battery industry without delivering any additional benefit in control of risk to human health."
Lead-based batteries are sealed units that operate in Europe in a closed loop with almost 100% collected and recycled at the end of life. Their submission shows that during the manufacturing phase of lead-based batteries, all four compounds are transformed into other substances with only trace amounts (<0.1%) present in the finished battery.
Furthermore lead-based batteries are also essential for the needs of all current and future generations of vehicles, be it cars, trucks or powered-two wheelers - the current European vehicle park of around 275 million vehicles relies on lead-based battery technology and there are no drop-in alternatives.
In addtion lead-based batteries are essential in a number of areas as a source of back-up power, contributing to the effective functioning of communications, IT, production & distribution of renewable energy, nuclear safety, oil and gas networks and for the storage of data in uninterruptible power supply as well as other industrial systems. They are also widely used in agricultural, construction and lawn & garden machinery.
Requesting the granting of an exemption the industry explained that the use of these lead compounds in battery manufacture meets all the requirements of Article 58(2) exemption from REACH authorisation
Specific Community legislation imposing minimum requirements relating to the protection of human health or the environment that ensures proper control of the risks is already in place. While existing legislation provides binding and enforceable minimum requirements for the control of risks from the industrial use of lead compounds in battery manufacturing.
For instance, pressure for substitution of the workplace use of lead already exists through the hierarchy of controls in the Chemicals Agents Directive and legislation for the use of lead-based batteries through the provisions aimed at substituting heavy metals in both the Battery Directive and the End-of-Life Vehicles Directive.
In its statement to the Commission the industry stated: "We believe that including a REACH authorisation requirement for the use of lead compounds in the manufacture of lead batteries is not a proportionate regulatory action and would significantly undermine the competitiveness of the European battery industry without delivering any additional benefit in control of risk to human health."
The importance of automotive and industrial lead-based batteries to the European economy
A study, prepared for the ongoing review of the current exemption for lead-based batteries within the End-of-Life-Vehicles Directive’s wider ban on lead in light-duty vehicles, found that there are at present no alternatives, either technically or economically, to lead-based batteries for the SLI (Starting – Lighting –Ignition) function in vehicles. This means lead-based batteries are essential in virtually all conventional ICE (internal combustion engine) vehicles (1For vehicles the application category AC1 applies). Also today’s hybrid vehicles (Mild, micro, plug-in-HEV, PHEV) and full electric vehicles do have a demand for lead-based batteries for important functional requirements. Lead-based batteries also serve as SLI batteries in agricultural, lawn & garden tractors.
Notes to editors
Why lead-based battery use should be exempt from REACH Authorisation
The European battery industry believes that the use of lead monoxide, lead tetroxide, pentalead tetraoxide sulphate and tetralead trioxide sulphate for production of lead-based batteries should be granted a REACH Article 58 (2) exemption on the following grounds:
About the industry partners
EUROBAT is the association for the European manufacturers automotive, industrial and energy storage batteries. EUROBAT has 52 members from across the continent comprising more than 90% of the battery industry in Europe. The members and staff work with all stakeholders, such as battery users, governmental organisations and media, to develop new battery solutions in areas of hybrid and electro-mobility as well as grid flexibility, renewable energy storage and demand response services www.eurobat.org
International Lead Association (ILA) is a membership body that supports companies involved in the mining, smelting, refining and recycling of lead. The ILA represents the producers of about 3 million tons of lead. ILA’s work has a broad focus, covering all aspects of the industry’s safe production, use and recycling of lead. The organisation manages the Lead REACH Consortium and supports the work of the Advanced Lead Acid Battery Consortium.
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