Avenue Marcel Thiry, 204
B1200 Brussels, Belgium
Tel: +32 2 774 96 53
Fax: +32 2 774 96 90
Eurobat position on car batteries in REACH
On behalf of the European automotive battery industry and in the context of the ongoing
discussions on REACH (RIP 3.8), Eurobat would like to present the following arguments
regarding the definition of car batteries:
Car batteries need no maintenance from the car owner. The only personnel which may
be involved from time to time in maintenance operations are trained professionals.
Under normal or reasonably foreseeable conditions of use, there is no intention of
preparation (electrolyte) release.
Car batteries can therefore not be considered as containers with a substance inside and
even less as a substance or preparation as defined in Article 3.1 or 3.2 of REACH.
Car batteries are articles as defined in Article 3.3 of REACH.
Eurobat calls upon the European Commission to implement a simple and realistic
definition of car batteries in the framework of REACH. Car batteries are articles as
defined in Article 3.3 of REACH and not substances or preparations as defined in
Article 3.1 or 3.2 of REACH.
Eurobat is the representative association for automotive and industrial battery manufacturers and their suppliers,
the collective voice of over 30 European operations employing around 30,000 professionals in Europe.
For questions or further information, please contact Pierre Conrath at Eurobat, email: firstname.lastname@example.org, tel. +
32 2 774 96 53