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The Extended Producer Responsibility (EPR) is an environmental policy approach in which a producer’s responsibility for a product is extended to include the post- consumer stage of a product’s life cycle.
An important element of the EPR policy is the shifting of end of life system responsibility, operational and financial, upstream toward the producers. It also intends to give incentives to producers to take into account environmental considerations when designing their products.
While producers of batteries assume this responsibility, a transparent communication of the costs related to the management of the waste products will enforce the effects of the EPR policy.
Separately invoicing these net collection and recycling costs will benefit the environment, consumers, authorities and all economic actors involved in the distribution of the new batteries.
In particular, the visible fee guarantees the financing of the development of a collection network with a sufficient density for effective collection of all batteries, regardless of the chemistry, and of the required communication campaigns to create consumer awareness of this collection network. This leads to consumer convenience, which is essential to achieve the environmental objectives, without having an impact the commercial relations between the economic actors.
When the net costs related to the collection and recycling of the waste batteries are invoiced separately, the profit margin of the different steps in the distribution chain will not be calculated on the environmental fee. This way, the impact of the cost financed by the producers on the consumer prices can be limited.
A visible fee on the invoices of the economical actors simplifies the market surveillance activities of the national authorities that have to ensure all producers take their responsibility in organizing and financing the collection and recycling network.
Separately invoicing the net collection and recycling costs related to waste batteries will benefit the environment, consumers, authorities and all economic actors involved in the distribution of the new batteries.
In particular, it guarantees the financing of the development of a collection network with a sufficient density for effective collection of all batteries and of the required communication campaigns to create consumer awareness of this collection network, and it simplifies the market surveillance activities of the national authorities, without having an impact on the commercial relations between the economic actors.
Eucobat proposes that Member States be allowed to require a visible compliance fee to be mentioned on invoices from producers to purchasers of batteries. The visible compliance fee shall include all costs for collection, sorting, treatment, monitoring, reporting, communication, sensibilisation and management incurred by the producers or by third parties acting on their behalf. The costs mentioned shall not exceed the best estimate of the actual costs incurred. The mandatory visible compliance fee applies only to batteries for which producers actively organize collection.