Document 2Rqx863bRMmmr5KN2gMxO1KbL

V=SA0 EBRA fcec EVES EUROBIAB Twps|rpocoznr EzooVovAornon: EA TaL Eurometaux MS RECHARGE eurol wim. RE LITHIUM en `To: Frans Timmermans, EU Executive Vice-President for Green New Deal; Maros Sefovi, Vice President for Strategic Foresight; Virginijus Sinkeviius, Commissioner for Environment; Thierry Dear Executive Vice President Frans Timmermans, Vice President Maro Sefcovi; Commissioner Virginijus Sinkevicius; Commissioner Thierry Breton, about the European Chemicals Agency's Risk Assessment Committee proposal to classify three In our view, the scientific evidence is too weak and does not justify such a severe classification, 1Adiassification for thethree lithium salts and calls for a re-evaluation at the scientific level. or different investment decisions towards competing markets. It will: * Make the lithium salts eligible as EU Substances of Very High concern, facing a trend fe Our industries are committed to safely manage hazardous materials, and we engage constructively in the EU's classification and REACH processes. But in this case, we have serious concerns about our view itis based on weak and incomplete evidence from studies, not conducted according to. recent guidelines and missing key evidence. `Today's discussion i also an example of wider needforcoordination between Europes raw `materialsgoalsand its chemicals legislation.Most metals needed in Europe's batteries and wider energy transition either have some direct hazardous properties or are alloyed with other hazardous materials. It's imperative that the upcoming REACH and CLP Review better aligns Europe's raw materials and chemicals goals. We would be pleased to discuss our proposals with you. Yours sincerely, About EBRA, the European Battery Recycling Association, represents the interests of actors involved with Sorting, treating and recycling consumer, industrial or automotive spent batteries,whateverthe type or chemistry, apart from Lead-Acid automotive batteries, but including E-mabity and stationary batteries.wewbra-recycling.org EGEC, the European Geothermal Energy Council is a not-for-profit organisation promoting all aspects of the geothermal industry. It was founded in 1998 to faciitate awareness and expansion of geothermal applications in Europe and worldwide by shaping policy, improving investment conditions and steering research. Over 150 members from 28 countries, including developers, equipment manufacturers, electricity providers, national associations, consultants, research centres, geological surveys, and public authorities ives EGEC the ability to represent the entire geothermal sector.EGEC is listed in the European Transparency Register No. 11458103335.07 For more information visit wun egec org EUROBAT is the leading association of European automotive and industrial battery manufacturers, coveringall battery technologies, and has more than 50 members. The members and staff work with al policymakers, industry stakeholders, NGOS and media to highlight the important role batteries play for decarbonised mobility and energy systems as well as all other numerous applications. wwweurobatorg EUROMETAUX is an industry association representing the collective European non-ferrous metals industry, includingminers, smelters, refiners, fabricators and recyclers. With 500,000 employees and an annual turnoverof12o0urmbemnbe,rs represent an essential industry for European society that businessesin almost everysectordepend on. Together,weare leading Europe towards amorecircular future through the endlessly recyclable potential of metals. www eurometaux be Euromines, the European Association of Mining, Meta Ores & Industrial Mineral, represents large and small companies and subsidiaries in Europe and in other parts of the world which provide jobs. to more than 350,000 people. Through the activites and operatioonfs these members, more than 42 different metals andmineraalrse produced.Their sustainable exploitation can increase Europe's supply of mineral resources, help ease imports from third countries usually applying lower environmental, corporate and social standards and foster the socio-economic growth of Europe's Regions. The European mineral raw materiols industry playas crucial role in the EU ability to nurture sustainable growth including access to and supply of raw materials, providing over 30 million jobs ainnfdorpmlaaytiinogn a key role in the development onww.eurominesorg o f moder n e nv ir onm en ta ll y fr ie ndl y technologies. More LiA, the International Lithium Association, was established in 2021 to be the representative global body for the lithium value chain. Our members produce around 75% of the total global supply of lithium, The Association's mission is to be the voice of the lithium industry and its key objectives are to represent, engage,educate and grow the lithium industry and maintain ts standingas a champion of sustainable and responsible supply. httos://ithium org! RECHARGEisthe European industry association for advanced rechargeable and lithium batteries Founded in 1998, itis our mission to promote advanced rechargeable batteries aa key technology that will contributeto a more empowered, sustainable and circular economy. RECHARGE's unique membership covers all aspects of the advanced rechargeable battery value chain in Europe: from suppliers ofprimary and secondary raw materials, to battery, equipment and original equipment manufacturers (OEMs), to logistic partners and battery recyclers. www.rechargebatteries.org