Notice to Members

Dear friend* and supporter*!

please read this – also because of my conviction about the foresight of EU legislation – very competent notice.  And thank you for your votes so far. The author of this notice promises that the EU is already, or will be shortly, in place. Well, his words may be true. We should continue persistently question how our e-cars, e-apartments life will look like, which e-car model is wanted by us. We as humans should further remind legislations and car-manufactories to produce e-cars and power packs/banks in such a way that e-power is usable for all use cases/scenarios instead of only motorsport and rich-people use cases!

The original notice – es well as – the request can be found there

And don’t take yourself too seriously when driving yourself, this is not the sharing path that we should go!

1. Summary of petition

The petitioner claims that battery production for electric cars is proving to be very harmful to the environment. In addition, he points out that the weight of electric vehicles increases due to heavy batteries and that these batteries are dangerous in the event of accident. He therefore calls on the European Union to adopt measures in order to reduce the overall environmental impact of tonne-heavy batteries. In this regard, he suggests that a ‘payload to battery weight’ ratio be taken into account in the tax levies and that electric cars be loaded with an e-trailer or a ‘drivingPowerPack’.

2. Admissibility

Declared admissible on 28 May 2021. Information requested from Commission under Rule 227(6).

3. Commission reply, received on 3 December 2021

While it is critical, as the petitioner suggests, that the production of batteries is done in a way that has the smallest impact on the environment as possible, it is also important to remember that electric vehicles (EVs) have a major environmental benefit compared to those powered by internal combustion engines (ICE). In particular, there are no tailpipe emissions of air pollutants or carbon dioxide when in use and, as studies (1) show, associated well-to-wheel greenhouse gas emissions are generally lower than those of comparable ICE vehicles. The rapid decarbonisation of the electricity sector in the EU will contribute to EVs becoming more beneficial over time with regard to the carbon footprint of their direct energy consumption as well as of the battery production. EVs appear today as the main, and highly cost-efficient route, towards the decarbonisation of at least the passenger car and light commercial vehicle sectors. As such, they will play a key role in the transition towards zero-emission mobility essential to achieving the 2050 climate-neutrality objective.

Regarding the environmental cost associated with producing batteries, with the rapid pace of technological developments, this environmental impact is falling as is the cost of this technology. There is also a major effort by the industry and supported by the Commission, primarily through the planned legislative proposal (2) (referred to below), to reduce the environmental impact of battery manufacturing. Gigafactories also allow for economies of scale that will reduce the costs still further.

The Commission, in December 2020, adopted a comprehensive proposal for a new legislative framework on batteries that will have sustainability requirements at its core. This is currently being discussed with the European Parliament and the Council. These requirements are likely to include the responsible sourcing of raw materials, incentives for the placing on the market of low carbon batteries and minimum levels of recycled content of some key materials. Subject to these discussions, the Commission expects that the legislation will be agreed by the end of 2022.

In terms of safety linked to the increased weight of EVs, the Commission is aware of this issue, and measures to mitigate these risks have been included in the revised General Safety Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on type-approval requirements for motor vehicles (3)

In particular, measures have been introduced to reduce both the severity of crashes, by lowering overall driving speeds through the implementation of intelligent speed assistance systems, as well as by significantly reducing crash speeds or by avoiding accidents altogether through the implementation of advanced emergency braking and emergency lane keeping systems. The new measures apply from 6 July 2022 for all new EV models introduced onto the EU market and as from 7 July 2024 for all new EVs sold in the Union. The Commission doubts that there will be a significant safety benefit attributable to towing batteries behind a motor vehicle instead of them being wholly integrated in that motor vehicle.

In the area of passenger car-related taxes, there is almost no harmonisation at EU level. Consequently, as a rule, Member States have freedom in deciding how to apply such taxes, provided that they comply with EU law. As regards the petitioner’s proposal on a specific tax, the Commission will consider it in the wider reflection on environmental taxation.


The petitioner raises a number of important issues in relation to electric vehicles, concerning their environmental impact and their safety. However, the Commission believes that these are being adequately addressed through technological developments and EU legislation that is already, or will be shortly, in place.

Links in this notice

  1. An example is a study by Ricardo Energy & Environment on “Determining the environmental impacts of conventional and alternatively fuelled vehicles through Lifecycle Assessment”;
  2. COM(2020) 798 final;
  3. Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users, OJ L 325, 16.12.2019, p. 1. 

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