Competition in Compliance

Eucobat Positions
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Eucobat fully adheres to the principles of free and fair competition.

In general, a competitive system with multiple competitors leads to an improvement of efficiency and innovation and to a greater choice for the producers of the batteries. 

There are however some risks linked to an unregulated competition. As convenience for the consumer when disposing off batteries is a key success factor for the collection of discarded batteries, providing and servicing a dense network of collection points is of the utmost importance. But the harder the competition, the more the efforts of competing schemes to collect the batteries at the lowest costs will prevent the development of a nationwide collection network with a service for all collection points. The focus will be in this case on high performing collection points and on battery chemistries with a positive residual value (e.g. lead batteries) instead of collection points in poorer populated regions and battery chemistries with a (high) negative residual value (e.g. alkaline or lithium batteries).

A system managed by one single compliance organization can focus on quality besides the cost element. It also ensures greater transparency as the communication towards consumers, collection points, companies and member states is unique and thus coherent. For the operational costs, this system creates economies of scale, which will bring it greater negotiating power when issuing tenders for operational tasks, such as logistics, sorting and recycling. This negotiation position can result in competitive prices, which will benefit the cost-efficiency of the system. A potential risk of a mono compliance organization with a non-profit status is the lack of challenge from the market, which could result in less efficiency in the long term. The well-considered composition of supervisory boards can contribute to keeping compliance schemes dynamic and efficient. A supervisory board composed entirely out of producers will always strive for competitive prices for the services offered. 

Eucobat Position

Eucobat fully adheres to the principles of free and fair competition. 

A level playing field with uniform standards is required to ensure this fair competition.  

In order to ensure a high level of efficiency and performance and taking into account the specificities of each country, member states need to ensure that:

  • All waste batteries are collected, including the batteries with a negative residual value and those discarded in poorer populated regions.
  • Cherry picking is avoided, as well related to the battery chemistries as to the collection points.
  • Communication is a shared responsibility of all compliance organizations and all producers, that are accountable for a contribution.
  • A collection network with sufficient collection points ensures the consumer convenience.
  • Each compliance organization and each producer makes the necessary efforts, so the mix of waste batteries collected corresponds to the mix of batteries put on the market by him or by the affiliated producers.

To this extent and to ensure a fair competition between producers, compliance schemes and suppliers, a nationwide coordination is required without distorting the competition between the schemes.

This could be realized by a national coordinating body that coordinates and monitors the respect of the uniform standards for collection of waste batteries and the communication towards consumers. This coordinating body should be jointly managed and financed by all the compliance organizations and report to the national authorities.