The EU Battery Regulation - sustainable and circular batteries to support EU's energy transition

Agenda for
21-23 June

Karsten Kurz
Director Environmental Affairs, Europe, Exide Technologies GmbH, Germany
The upcoming EU Battery Regulation is the first holistic piece of product legislation that was prepared under the Green Deal program of the Commission of von der Leyen.
It will have a significant impact on the sourcing of raw materials, product design, manufacturing, product information and stewardship, end-of-life management and company’s structure and operations.

It is the intention of the Battery Regulation to guarantee that Europe’s decarbonisation efforts will be supported by sustainable batteries.

However, can it keep that promise?

Today, no one knows. It’s now two and a half years since the European Commission published the proposal for the Regulation. After a period of intense discussions with all involved stakeholders and a trialogue that closed six months ago, we expect the Regulation to enter into force later this year.

The Regulation is challenged by missing secondary legislation that will provide the practical details that will be necessary for full implementation. This will be developed over the coming years, and we need to remain vigilant to make sure the new rules deliver stated objectives in a manner that does not create additional red tape or disadvantage EU manufacturers that operate in a global marketplace.

The requirements for the end-of-life management will be based on the principles for environmental legislation; hence, Members States have some freedom to add additional requirements. This is a drawback and a missed opportunity, especially as we are talking about the already significant requirements under the extended producer responsibility principle.

Pb2023 is the major event of the lead industry, hence there is logic in asking whether the Battery Regulation has the potential to reduce some of the legislative burden in managing to lead. While we meet in Athens, the European Commission is preparing parts of the answer to that – on June 21st we expect the publication of the Commission proposals for the new End-of-life vehicle Regulation. Will the Commission continue regulating batteries in multiple parallel pieces of legislation or will we see a wise decision with batteries removed for the scope of ELV so that the Battery Regulation becomes the main tool to drive sustainable EU battery production and use?

Can the Battery Regulation become a piece of legislation that helps grow a competitive EU industry, or will it be a tool that attempts to micro-manage our sector? It is still up to us and our partners to have a positive outcome here.


After Karsten graduated as an engineer for Environmental Technologies and Industrial Hygiene, he started working as the EHS Manager for Accumulatorenfabrik Sonnenschein – a German manufacturer of a lead- and lithium based batteries. Over the years he gained experience in EHS Management Systems, EHS compliance and Blood Lead Mitigation Programs as well as Environmental Remediation. In 1995, Exide came into play. Not only that Karsten could extent his scope to Europe, the more important was that Exide was able to provide the complete service – manufacturing and recycling of batteries of various technologies. Since the early 2000’s Karsten served as EHS Director for Exide in Europe and started representing his company in EHS and Sustainability working groups of several European Industry Associations such as EUROBAT1 and the ILA2 . At this time, Karsten was already a stakeholder in the process to develop the current Battery Directive. In his current position as Director Environmental Affairs Europe, he oversees the engagement of Exide in the Stakeholder Advocacy Programs. With the beginning of 2015 Karsten took the lead of the Exide’s CSR Team. Karsten is member to the Steering Committee of the Lead REACH Consortium and chairs the EHS cluster of EUROBAT.