EUCOBAT and its members are located both downstream of the production and consumption, and upstream of the processing of waste batteries. Drawing on lessons learned from this operational position in the value chain, we welcome the Commission’s initiative to modernise the EU’s batteries legislation and we are calling for the modification of key provisions of the current "Batteries Directive”.
The new regulatory framework should be based on market realities in order to guarantee the best efficiency possible in the management of waste batteries. From this perspective and as highlighted during the consultation activities, here is what we recommend regarding collection of waste batteries, extended producer responsibility and recycling.