FEM-PP-210713-EC-proposal-for-a-Regulation-on-batteries-and-waste-batteries

European Materials Handling FederationPosition PaperFEM comments on the European Commission proposalfor a Regulation on batteries and waste batteries13July2021FEM represents European manufacturers of materials handling,lifting and storage equipment.Our membersmanufacture equipment that enables the movement,storage,control and protection of materials,goods,and products.Our industry delivers organisational and technical solutions for efficient and sustainablematerials flow throughout the supply chain.The materials handling industry covers various types of equipment,both stationary and mobile,powered bydifferent types of energy sources,including batteries.Besides the equipment,our industry also manufacturesbattery packs for mobile applications,such as shuttles,cranes and industrial trucks.Consequently,severaltypes of FEM equipment will be impacted by the proposed requirements for batteries and waste batteries.FEM acknowledges the need to modernise the EU legislation on batteries.Our industry supports theobjectives of the European Commission proposal,which aims at strengthening the Internal Market througha common set of rules,promoting circular economy,and reducing environmental and social impacts ofbatteries.In addition,FEM strongly believes that the future regulation should aim to accelerate innovation andstrengthen European competitiveness.Our manufacturers are world leader for most of materials handlingequipment and integrated systems,and industrial mobile battery applications in our sector are mainlydeveloped in Europe.To ensure a future regulation of high quality,the European Commission proposal should be revised accordingto the better regulation principles.In short,the legislation must strengthen the competitiveness andsustainability of the Union's economy,in the simplest,most efficient,and effective way possible,whilstavoiding overregulation and unnecessary administrative burdens,and finally be designed to facilitate itstransposition and practical application.FEM identified necessary improvements in the European Commission proposal to achieve a legislativeframework meeting the better regulation principles,contributing to the Single Market and enhancinginnovation-essential elements for the EU competitiveness and sustainable growth agenda.Indeed,ashighlighted in the EU industrial strategy,supporting innovation is essential to maintain the globalleadership position of the European materials handling industry.To shape a balanced and supportive legislative framework,FEM identified the following improvementsin the European Commission proposal:1.Establish clear definitions to ensure a common understanding for the implementation andenforcement of the future legislationFEM AISBL,DIAMANT BUILDING,BD A.REYERS 80,B-1030 BRUSSELS WWW FEM-EUR COMFEDERATION EUROPEENNE DE LA MANUTENTION EUROPEAN MATERIALS HANDLING FEDERATION-EUROPAISCHER VERBAND FOR FORDERTECHNIK FEDERAZIONE EUROPEA DELLA MOVIMENTAZIONE E DEL SOLLEVAMENTOTet:+3227068237Fax:+3227068250E-mail: