Producer Definition

Eucobat Positions
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PP Producer Definition - Sum.pdf 831.15 KB

Issues

The producer definition, as described in the Battery Directive, does not comply anymore with the evolution of the battery market.

The Battery Directive does not offer a solution for the substantial, and growing, international trade by means of distance communication, in particular internet sales to consumers. For the batteries put on the market in this way, no producer is responsible and in many cases the take-back is organized and financed by other producers. As a consequence, fair competition and a level playing field for all economic actors becomes impossible.

More and more batteries are put on the market integrated in an electrical appliance. Different definitions of the producers will lead to confusion and administrative burden, when for an appliance with integrated batteries, another economic actor might be considered as the producer of the integrated batteries than the producer of the appliance.

Eucobat Position

In order to avoid administrative burdens, a harmonisation is thus required between the Battery Directive and the WEEE Directive.

As the WEEE Directive complies most with the evolution of the market, Eucobat proposes to align the producer definition with the WEEE Directive and to introduce also the concept of the ‘authorized representative’ in the Battery Directive.