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Batteries are increasingly used in all sorts of electrical and electronic products, which impacts their end-of-life treatment and often gives rise to thermal events. In 2019, a number of organisations representative of the industry that manages the collection and treatment of spent batteries and waste electrical and electronic equipment (WEEE) and of the manufacturers of home appliances and consumer electronics, gathered to exchange views about the growing issue of fires associated with WEEE that contain batteries, in order to design measures to address the problem. A survey was designed for pan-EU stakeholders to better understand the issue of fires in the WEEE management chain and collect good practices.

Eucobat welcomes the Commission’s initiative to adapt and modernise the legal framework for the entire life cycle of batteries, which are one of the key enablers for sustainable development and green mobility, clean energy and climate neutrality, contributing to the Green Deal objectives. 

From this perspective, here are the recommendations of Eucobat pertaining to several aspects of the proposed Regulation.

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.

The Digital Services Act represents a very good opportunity to bring sustainability into the digital debate, in line with the European Green Deal. EucoLight, Eucobat and EXPRA therefore welcome the reference to sustainability in the IMCO report led by MEP Saliba and would like to share some additional recommendations.

Still, for the sustainability angle in the Digital Service Act to be comprehensive, it should include both provisions on providing clear information to consumers and ensuring that producers contribute financially to the costs of waste management.

The Eucobat Position Paper on the Collection Target has been updated with new the most recent figures.

The core message remains the same: a collection target can only be adequate if it is related to the quantities of waste available for collection.

A directive is an act that sets a goal for all Member states to achieve, such as was the case with DIRECTIVE 2006/60/EC. The individual states were charged with the responsibility to create their own laws to meet the goals specified in that directive for creating a EPR system throughout the EU.

A regulation is a binding legislative act that requires all Member states to follow. It must be followed in its entirety throughout the EU. 

Therefore, simply put, a directive provides a framework for individual Member states to create their own national laws, while a regulation is a law that will apply in all EU countries. 

Primary batteries, today, provide growing levels of power while being smaller and using less materials than previous generation’s batteries. Since 2006, the environmental impact of primary batteries has even further decreased by implementing the collection obligation as set in the Batteries Directive 2006/66/EC. 

All waste primary batteries brought to a collection point are also effectively recycled. It is therefore with great concern that we see voices calling for a potential ban on primary batteries.

Eunomia published its Study to support preparation of the Commission’s Guidance for Extended Producer Responsibility Schemes. It sets out the recommendations and their rationale, based on stakeholder engagement and analysis of the different approaches taken across Europe and their merits.