Eucobat Position on JRC Study
Collection targets for waste portable batteries and waste light means of transport batteries
Eucobat welcomes the JRC study pertaining to alternative collection targets for waste portable and light means of transport batteries1, and is pleased that its feedback provided during the workshops has been taken into account by the Joint Research Centre and the European Commission.
• Calculation methodology of collection targets
This timely study is essential and demonstrates the inadequacy of the current calculation methodology of collection targets, known as ‘Put on the Market’ (PoM). Indeed, as the JRC study points out, for both portable and light means of transport batteries (LMT), there will be a growing discrepancy between the volumes of batteries which are placed on the market and the waste battery volumes becoming available. In addition, the JRC also emphasizes that ‘the limits of the POM based approach could be reached soon’, especially in the case of light means of transport batteries.
Eucobat supports the JRC’s recommendation to modernise the calculation methodology of collection targets, i.e, to change the current calculation methodology based on Put on the Market to a calculation methodology based on ‘Available for Collection’ (AfC).
Adopted fifteen years ago, the current calculation methodology of collection targets based on PoM no longer corresponds to the current and future battery market. Indeed, it consists in calculating the total weight of portable batteries placed on the market in the last three years within a Member State. However, there is no correlation between the amount of batteries put on the market and the amount of waste batteries available for collection within three years from their placing on the market.
Therefore, the current calculation methodology of collection targets based on ‘Put on the Market’ does not align with objectives set out in the New Circular Economy Action Plan and in the Green Deal, which should aim for and take into account the growing lifecycle of batteries and the improvement of their sustainability.
Eucobat and its members strive for a better environment by collecting ever more used batteries and by recycling them ever better, however Eucobat members can only collect the waste batteries which are available for collection.
As such, Eucobat highlights the necessity to change to a calculation methodology based on ‘Available for Collection’, taking into account the lifecycle of batteries, the export of second hand electrical and electronic equipment, as well as the export of waste electrical and electronic equipment (WEEE), allowing to set realistic and achievable collection targets.
Moreover, while Eucobat understands certain concerns which have been raised concerning the feasibility of this new calculation methodology, it is crucial and worth noting that the JRC stresses that the market assessment undertaken, as well as the stakeholder feedback provided for its study ‘constitute a sufficient analytical basis for developing a common methodology for the calculation rules for an AfC alternative’.
In addition, it is essential to highlight that the JRC deems the change towards an ‘AfC’ calculation methodology ‘feasible and beneficial in anticipation of highly uncertain future waste amounts’.
In this context, Eucobat is definitely in favour of the Option B recommended by the JRC, namely to establish a calculation methodology based on ‘Available for Collection’ for both portable batteries and the new category for light means of transport batteries.
Based on the JRC’s assessment with regards to the feasibility of the methodology and the sufficient material to develop it, Eucobat calls to establish the ‘Available for Collection’ calculation methodology for both portable and light means of transport battery categories from the entry into force of the Regulation.
Setting this calculation methodology as soon as possible will allow its full development by taking into account all variables from the start, namely battery lifecycle, export of WEEE and export of second hand EEE, and will incentivise all actors concerned to provide existing data and to produce data, allowing for a realistic representation of waste battery flows.
With regards to the Options A or C put forward by the JRC (respectively Potentially Available for Collection and a first adoption of PAfC followed by AfC), Eucobat recalls that adopting a calculation methodology based on PAfC could hamper the production of data on non-collectable flows, as there would be no guarantee that actors concerned across the value chain would be incentivised to produce data on those flows, in addition, only the lifespan of batteries would be taken into account, leading to collection targets which still do not represent the reality of the market. Those options would lead to a delay in the adoption of a complete methodology based on Available for Collection, thereby not allowing a realistic representation of the waste battery flows and of the battery market despite their important evolution.
As an example of the need to immediately evaluate and take into account those flows, we can cite the ProSUM study which stated that at least 45.000 tonnes of the batteries “end-of-life” are exported from the EU, representing an important share of batteries not available for collection in the European Union (around 19% of ‘end-of-life’ batteries as calculated in the Möbius-Eucobat study.
Furthermore, given that this new Regulation aims at promoting a circular economy approach, it would make sense to establish the calculation methodology ‘Available for Collection’ from the entry into force of the Regulation. In addition to reflecting more realistically the waste battery streams, it would also provide a better picture on the mass flows of battery raw materials, as highlighted by the European Commission in its impact assessment.
Overall, specific provisions from the start in the Battery Regulation concerning the calculation methodology ‘Available for Collection’ and the associated reporting from the concerned actors could guarantee co-legislators and the European Commission that data would be provided, ensuring that this new forward-looking legislation on batteries and its collection aspects contributes as best as possible to the objectives set out in the New Circular Economy Action Plan and of the Green Deal.
• Light means of transport battery category
Eucobat welcomes that the JRC identifies as a ‘future-proof combination’ the creation of a new separate category for light means of transport batteries in-between the portable and electric vehicle battery categories, together with the calculation methodology based on ‘Available for Collection’.
In light of the many new appliances coming onto the market, such a combination definitely constitutes the way forward and brings clarity.
The new category would enable a clear focus on e-mobility and ensure the optimisation of the collection network, since LMT batteries are very different from portable batteries in terms of size, weight and lifecycle (an e-bike battery lifecycle can last up to 10 years) as well as require different handling and safety requirements.
With regards to the definition of this new category, Eucobat believes that the establishment of a weight threshold to distinguish the light means of transport category and the electric vehicle category is relevant. In this regard, the range of weight thresholds suggested by the JRC to distinguish light means of transport batteries and electric vehicle batteries would be appropriate, but should not be higher than 25 kg4.
Furthermore, Eucobat highlights that a reference to type-approval legislation is also appropriate to distinguish LMT batteries from portable and EV batteries (Option 2A put forward by the JRC). To that end, Eucobat proposes to establish a separate LMT category which would include batteries of L1 and L2 vehicles, as well as batteries of non-type approved vehicles such as e-bikes, e-skateboards, unicycles, hoverboards, to name a few.
For this new separate category, Eucobat believes the aim would be to keep the focus on personal electric transport devices/vehicles. Therefore, including the rest of the L categories (L3 to L7) might be difficult, since the vehicles concerned could be more defined as electric vehicles rather than light means of transport. For example, the L3 category corresponds to two-wheel motorcycles, going to L7 which are ‘heavy quadricycles’ (such as quads, buggies, cars which do not require a driving license).
We also take note of the JRC’s suggestion (Option 2C) to combine the references to type approval legislation with a weight threshold in order to distinguish LMT batteries and EV batteries, which could constitute an interesting option to clearly define this new category.
On another note, a clarification would be required to indicate why the JRC chose the collection targets proposed by the European Commission for portable batteries as a reference for collection targets of a new separate category for light means of transport battery.
For the suggested Option 2, the JRC proposes two identical ‘‘Available for Collection’ targets to be set for the portable category and the light means of transport category, with a revision clause to adapt two individual collection targets.
However, we believe it is necessary to define two separate and different collection targets from the start, as the same level cannot be expected for a newly created category of batteries which in most cases requires a specific organisation of collection network in order to fit with the specificities of the light means of transport batteries, notably their size, weight and lifecycle. We emphasize that before fixing targets the feasibility to obtain those targets must be examined.
Lastly, the definition for electric vehicle batteries suggested by the JRC does not include batteries of vehicles of the T categories (tractors) nor batteries of non-road mobile machinery (for instance bulldozers, excavators, dumpers etc…). However, given the growing ‘electrification’ of those vehicles, Eucobat believes it would be relevant to also include them in the definition. As an example, batteries of electric tractors could be similar to the ones used in electric busses, hence the need to evaluate the possibility to include those categories as well.
Eucobat aisbl is the European association of national collection schemes for batteries. They assure that all waste batteries are collected and recycled in an ecological sound way, and contribute this way to a better environment.