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Position paper - Cross-industry statement on the need for a transition period for the implementation of the Batteries Regulation

22 Jul 2021


The co-signatories of this joint statement support the European Commission’s objective to improve the sustainability of batteries, while protecting the competitiveness of the Single Market, and are fully committed to supporting the EU’s transition towards sustainable batteries.

Given the extent of the changes and the significant uncertainty over the final text of the Regulation, we call on the co-legislators to provide economic operators with the necessary time to duly implement due requirements. This is especially the case for provisions with design impacts (e.g. Article 11 on battery replaceability) or labelling impacts that currently are foreseen to apply as of entry into force with no time for industries to re-design complex products and adapt complex global supply chains.

Within our statement we recommend to:

  • Introduce a transition period to ensure individual provisions are applicable no earlier than 24 months after the adoption of the corresponding Guidance, delegated or implementing act; and
  • Introduce a 24 month transition period (Art. 79 or 78 of the proposal) between the entry into force of the Regulation and its application, by replacing the current date of application that is set for 1 January 2022.


AmCham EU – American Chamber of Commerce to the EU

APPLiA – Home Appliance Europe


EGMF - European Garden Machinery Industry Federation

EPBA – European Portable Battery Association

EPTA – The European Power Tool Association

EUROBAT – Association of European Automotive and Industrial Battery Manufacturers

FEM – European Materials Handling Federation

MedTech Europe - the European trade association for the medical technology industry.

ORGALIM – Europe’s Technology Industries

TIE – Toy Industries of Europe