Hazardous Chemicals in EV Batteries: the Middle Ground That Will Make the EU Green Deal Successful

By: Maxime Castes, EHS Manager, EUROBAT 

In recent years, the potential health risks associated with battery raw materials have emerged as a significant concern among stakeholders and, consequently, a focus point of European legislation. This underscores the tension between the climate goals of the European Green Deal and the EU’s targets for reducing the use of hazardous substances in products and supply chains. 

EUROBAT has been fully supporting the Green Deal and actively contributing to shaping it since its inception. Recognising batteries as a critical component for achieving the Green Deal objectives, EUROBAT consistently advocates for battery materials exposure limits to be set at a level ensuring the protection of workers while allowing Europe to continue cutting emissions through the multiple applications of batteries. 

The next EU legislative term will need to introduce consistency across legislation regulating battery metals if Europe wants to establish itself as a cleantech hub and continue its journey towards a sustainable and decarbonised economy.  

Why do EV batteries contain hazardous substances? 

Batteries rely on using several substances classified as hazardous to perform their function – generating electric current. 

In a battery cell, electricity is generated via oxidation and reduction: two types of reactions in which molecules absorb or release electrons, depending on the cycle of the battery. During the discharge, electrons flow from the anode (negatively charged pole) to the cathode (positively charged pole), and vice-versa during the charge. Ions of lithium move between the anode and cathode through the electrolyte in a direction opposite to that of the electrons. 

Metal compounds are the materials of choice for active cathode and anode materials. Metals tend to release and recover electrons in a faster way than inorganic substances, enabling more efficient oxidation and reductions, the chemical reactions that drive electricity in a battery. 

Lithium, in particular, is the least dense solid element in the periodic table. This makes lithium a particularly efficient charge carrier in electrochemical applications for mobility, where range is a negative function of weight. 

The problem with battery materials

As most substances we use every day across a wide spectrum of applications, most metals are harmful to human health and the environment, depending on their exposure. The concern is also valid for Nickel Manganese Cobalt (NMC) batteries, which are the most common battery cathode material found in EV models today. Nickel, manganese, and cobalt have indeed all been classified as hazardous in the EU’s Classification, Labelling and Packaging (CLP) Regulation. While Lithium Iron Phosphate (LFP) batteries present fewer concerns, lithium compounds used as precursors for the manufacture of cathode active materials will likely be classified as harmful to human reproduction in the coming years [1]

Some battery inactive materials used to bind or stabilise the components of a battery cell, primarily the so-called per-and polyfluoroalkyl substances (PFASs), also present risks for human health and the environment. 

PFASs are ideal materials for batteries because of their persistence, although the same persistence can lead to soil and water pollution. The Commission is developing an EU-wide prohibition of the use of PFAS [2], which will take the form of a restriction under the EU’s chemicals Regulation “REACH”. The ban is set to enter into force in 2027, and manufacturers would need to substitute PFAS as soon as 2028 unless the industry secures a derogation. 

In October 2020, the Commission adopted a “Chemicals Strategy for Sustainability” [3], one of the key pieces of the Green Deal. The CSS sets Europe on a course to become “toxic-free” by 2030. The Strategy seeks to phase out “non-essential uses” of the most harmful chemicals in consumer products in the near term. 

The example of PFAS, in particular, is at the core of the contradiction between the climate pillar of the Green Deal and its Zero-pollution ambition. The very chemicals that will power the decarbonisation of the economy are increasingly under the radar of policy-makers for the risks they pose for workers’ health and the environment.

Zero Pollution and decarbonisation – holding the two pillars of the Green Deal together. 

The myriad legislation governing the use of hazardous substances in battery supply chains is becoming increasingly difficult to navigate. EU rules on chemicals are perceived by investors as one of the main factors preventing them from operating in Europe compared to other jurisdictions with more straightforward legislation. 

For instance, there is a risk that battery recycling businesses may explore alternative markets to establish their plants due to the upcoming EU workplace limits on cobalt and its compounds. Additionally, other markets might take advantage of uncertainties on the regulatory status of lithium compounds in the EU to lure investors away from Europe. 

The Commission is aware of the problem. The Critical Raw Materials Act [4] includes targets for the domestic sourcing of EV battery materials, and the Commission is also seeking to make EU rules on chemicals more predictable for battery supply chains through the introduction of the “essential use” concept [5], a fast-track derogation mechanism set to benefit lithium-ion batteries. 

The battery industry take: what the next EU political term should do  

The battery industry has a stellar track record of innovations and continues investing in making batteries more sustainable. For instance, nearly all lead batteries in the EU are collected and recycled at the end of their lifetime. 

The industry has also been investing in new battery technologies featuring fewer critical materials. For instance, sodium-ion batteries use salt as an active cathode material, and solid-state batteries will help reduce emissions of PFAS from battery supply chains. In the long run, fully organic batteries (using plastics to provide electrical power instead of metals) may help solve most challenges associated with metal-based batteries, from security of supply and EHS (Environment, Health, and Safety) risks in low-income countries to emissions of pollutants and workers’ safety. 

Meanwhile, clarity and consistency are needed for batteries to continue powering the Green Deal across the multiple pieces of legislation regulating battery circularity and design. In particular, workplace exposure limits for battery metals like cobalt or lead need to be set with great care so they can both protect workers in battery manufacturing and recycling plants and let the industry operate.  EUROBAT believes there should be no trade-off between human health and the EU Green Deal ambition and will continue working with policymakers to find exposure limits that ensure both priorities are taken care of.  

The next EU political term will be riddled with challenges from rising geopolitical tensions to elections in critical countries, the worsening economic outlook across jurisdictions, and the risks from the rise of artificial intelligence. However, climate action is poised to remain a key priority for the EU—and the world. Policymakers will have to continue ensuring the EU regulatory framework supports more cleantech development domestically if the EU wants to make progress on the road to climate neutrality.


A. Zimmermann and L. Cater, “Toxic or magic? Batteries industry freaks out over EU proposal to classify lithium as a toxin,” POLITICO, 14 July 2022. [Online]. Available: https://www.politico.eu/article/eu-commission-toxic-or-magic-batteries-industry-freaks-out-over-proposal-to-classify-lithium-as-a-toxin/. [Accessed 21 January 2024].


ECHA, “ECHA publishes PFAS restriction proposal,” European Chemicals Agency, 7 February 2023. [Online]. Available: https://echa.europa.eu/fr/-/echa-publishes-pfas-restriction-proposal. [Accessed 21 January 2024].


European Commission, “Chemicals strategy,” European Commision, 2020. [Online]. Available: https://environment.ec.europa.eu/strategy/chemicals-strategy_en. [Accessed 21 January 2024].


European Commission, “Critical Raw Materials: ensuring secure and sustainable supply chains for EU’s green and digital future,” 16 March 2023. [Online]. Available: https://ec.europa.eu/commission/presscorner/detail/en/ip_23_1661. [Accessed 21 January 2024].


CEFIC, “Defining Essential Use Of Chemicals – What Is At Stake?,” The European Chemical Industry Council, 2021. [Online]. Available: https://cefic.org/media-corner/newsroom/defining-essential-use-of-chemicals-what-is-at-stake/. [Accessed 21 January 2024].