FEAD feedback to the second workshop on the deposit-return systems for batteries
FEAD, the European Waste Management Association, welcomes the continued work of Oeko-Institut and Ramboll on the feasibility and potential benefits of deposit-return systems (DRS) for batteries under Article 63 of the Batteries Regulation.
FEAD particularly welcomes that the second stakeholder workshop identified fire prevention as the main driver for the discussion on a battery DRS, and focused the assessment on portable and light means of transport (LMT) batteries. This is consistent with FEAD’s previous input, which called for a battery DRS primarily designed to prevent fires, reduce misplacement of batteries, improve separate collection and retain critical raw materials in the European circular economy.
Following the second workshop, FEAD would like to reiterate its main recommendations while providing further evidence on the scale of battery fires, battery misplacement, collection infrastructure and practical considerations around reverse vending machines.
The DRS should cover all portable and LMT batteries, irrespective of chemistry
FEAD considers that the final consumer-facing scope of a battery DRS should cover all portable batteries and all LMT batteries, across all chemistries, including batteries embedded in electrical and electronic equipment (EEE).
Available evidence does not support limiting the fire-risk problem to e-cigarettes or other small portable batteries. Recent Austrian research highlights the increasing presence of lithium-ion batteries embedded in disposable e-cigarettes, toys, electric toothbrushes, power tools and other small electrical appliances in residual waste. At the same time, larger batteries also present a significant risk because of their greater energy content. German waste-sector research has directly identified e-bike batteries among batteries responsible for damage incidents, while the French ARIA accident database documents fires involving lithium bicycle batteries, including batteries incorrectly present in cardboard waste. Dutch government research similarly identifies battery packs, power-tool batteries and bicycle batteries as particularly relevant to fire risk from heavier lithium-ion batteries. LMT batteries should therefore remain within the scope of a battery DRS alongside portable batteries. The available evidence points towards different risk profiles: high-frequency misplacement of small embedded batteries and potentially higher-consequence incidents from larger battery packs.
Lithium-ion batteries are clearly the principal fire concern today and should therefore remain the priority. However, this risk-based prioritisation should not translate into a system in which only particular chemistries are eligible. Consumers cannot reasonably be expected to identify battery chemistry before returning a battery or a battery-containing product. A chemistry-specific eligibility system would make communication more difficult, create additional verification requirements at collection points and increase the risk that consumers continue to place non-covered batteries in residual or recyclable waste. The same applies to batteries embedded in products, for which the chemistry may not even be visible to the end-user.
The study itself recognises the considerable diversity of portable batteries and the need for an industry-based solution. FEAD therefore recommends a simple consumer message: all portable and LMT batteries should be returned through the appropriate collection system and none should be discarded in residual waste or other recycling streams.
Risk differentiation can take place within that common system. Higher-risk battery categories may justify higher incentives, additional storage requirements or earlier implementation. This would maintain simplicity for consumers while ensuring that the system design remains proportionate to actual risks.
For batteries embedded in EEE, the system should also avoid creating incentives for unsafe dismantling. Where the battery cannot be safely removed by the end-user, the complete battery-containing product should be eligible for return. This is particularly relevant for products such as earbuds, watches and other connected devices that are benefitting from the exemption to the removability of batteries by end-users under the Article 11 of the Battery Regulation. Today, around 90% of portable lithium-ion batteries are still embedded into devices.
FEAD continues to consider that SLI, electric-vehicle and large industrial batteries should not be the initial focus of such a DRS, as these batteries follow different collection, traceability and economic logics.
A battery DRS should not become a vape-only DRS
FEAD recognises the particular problem caused by disposable e-cigarettes. Their rapid growth, short lifetime, small lithium-ion batteries and frequent incorrect disposal make them an obvious priority for action.
However, a DRS limited to e-cigarettes would address only one small segment of a much broader battery-fire problem. While delivering some outcomes, a vape-only system could not become the end point of the Article 63 assessment. Any EU framework should be designed so that it can tackle the wider universe of portable and LMT batteries.
Scale of battery fires requires immediate action
Additional data gathered by FEAD members confirms that battery fires have become a major and rapidly growing operational risk for the European waste management sector. Based on available data from several European countries and an extrapolation to the EU-27 according to the volume of portable batteries placed on the market, FEAD estimates that around 17,500 fire incidents may have occurred in waste management in the EU in 2025, of which approximately 10,900 could be directly attributed to batteries. In addition, only around 1,100 of the estimated 10,900 battery fires in 2025 became publicly known (e.g. made it to the news). This means that for each fire people read about, nine more fires are happening but are directly managed by waste workers, often at risk to their own safety. For example, in Norway, only 4% of fires were handled by the fire service in 2025.
The economic impact is equally significant. Based on the available national cost data, FEAD estimates that battery-related fires damages could represent around EUR 2.7 billion in annual costs for the EU waste management sector in 2025, excluding investments in fire prevention. When expenditure on fire-detection and prevention measures is included, the total burden could reach approximately EUR 3.4 billion in 2025.
These figures should be understood as order-of-magnitude estimates rather than precise EU statistics. Fire-event definitions and reporting practices differ significantly between Member States, many incidents are extinguished internally and never reported to authorities or fire services, and the origin of a fire frequently cannot be established with certainty. There are also indications that insurance considerations may discourage the reporting of smaller incidents. The actual scale of the problem may therefore be higher.
Batteries misplacement in other waste streams
A DRS is needed to minimize as much as possible the batteries that are wrongly disposed in other waste streams, either residual waste or recyclable streams.
Previous FEAD evidence showed that an AI/X-ray trial at a lightweight-packaging sorting plant detected approximately 4.7 potentially hazardous battery or battery-containing items per tonne, or approximately one every 38 seconds during the trial. A recent Austrian study points in the same direction, with an average of 70 lithium batteries expected to be found in each waste collection vehicles,
France provides further evidence of the scale of misplacement. ADEME estimates that more than 7,100 tonnes of portable batteries were found in mixed municipal waste or in mixed dry recyclables streams in 2024, corresponding to approximately 20% of estimated portable battery waste generated. All Member States should have generated such data under the obligation of Article 69 of the Battery Regulation and they should share it publicly it to better understand the scale of the issue.
In Netherlands, it is estimated that approximately 1,460 tonnes of individual batteries (74 million units) are disposed of annually via household residual waste. In addition, an estimated 26 million batteries end up in the residual waste via discarded devices. In total, this involves about 1,980 tons and 100 million batteries per year. Compared to 2023 and 2024, both the tonnage and the number of batteries in residual waste have increased further.
In Italy, it is estimated that over 5,800 tons of Waste Portable Batteries and more than 100,000 tons of small Waste Electrical and Electronic Equipment would mistakenly end up in unsorted waste every year.
In order to improve the study, the DRS assessment should therefore include indicators such as the number of hazardous battery units diverted from residual and incorrect recyclable waste streams – thereby evaluating the positive impact on the waste sector.
Example of reverse vending machine in Latvia
A voluntary pilot developed by Wingo Deposit and tested in the Narvesen retail network in Latvia used automated recognition technology to identify returned e-cigarettes. According to the Latvian Ministry of Climate and Energy, the three-month pilot collected up to 500 e-cigarettes per day. Around EUR 400,000 was invested in developing the technology.
The pilot has since moved beyond a voluntary experiment. In June 2026, Latvia adopted legislation establishing a uniform national deposit system for electronic smoking devices with non-rechargeable batteries, planned to apply from 1 February 2027. A deposit of approximately EUR 0.50 is envisaged. Latvian authorities report that around 15 million disposable e-cigarettes were discarded in 2023 and that only around 5% were separately collected. The deployment of about 50 reverse-vending machines is expected through Latvia to cover the collection needs for the whole territory.
A unique QR code has been developed for each individual item to avoid the deposit being given back twice – an approach that FEAD supports for non-legacy batteries. Printing such QR code on each battery or e-cigarette during the production process, before it is placed on the market, is easy and not expensive. It is also the key to fraud prevention and efficient automated returns. Such system cannot address legacy batteries.
The Latvian assessment explicitly concludes that the pilot demonstrated the technical and economic feasibility of scaling the system nationally, provided appropriate investment is made, and identifies accessible infrastructure and consumer incentives as decisive conditions for success. Extension of the DRS system to AAA and AA batteries is expected in the years to come. Lithuania and Estonia are aiming at developing a similar approach, starting with the collection of vapes as well.
Additional information communicated to FEAD by Latvian stakeholders indicates an indicative current machine cost of approximately EUR 10,000 per unit for the pilot, but prices are expected to be much lower through larger-scale production. Although the current system is specifically configured for vapes, the technology can in principle recognise battery types beyond e-cigarettes, based on an AI-trained tool relying on weight, cameras and QR codes reading.
FEAD would like to stress that such reverse vending machines will have to be equipped in order to manage the fire-risk of the batteries they are expected to accept. Professional handling of larger quantities of lithium batteries currently requires controlled packaging and separation, including the use of appropriate non-combustible separation materials where necessary. Any battery RVM should therefore be designed and costed for such battery-specific safety requirements.
Legacy batteries must be incentivised from the beginning
FEAD reiterates that a system limited to batteries placed on the market after the introduction of the DRS would take too long to influence the fire risk currently faced by waste operators.
The Austrian Feldbach pilot provides useful battery-specific evidence. Consumers received a EUR 10 voucher for returning larger lithium-ion batteries or batteries contained in end-of-life devices. The pilot collected 425 lithium-ion batteries, around four times the number recorded in the previous year and neighbouring municipalities.
FEAD therefore continues to favour day-one acceptance of legacy batteries in a 0:1 return system, subject to appropriate anti-fraud safeguards. This is particularly important because the study itself acknowledges that long battery lifetimes can generate long system-transition periods and consumer deposit lock-in. For batteries put on the market once the DRS is implemented (e.g. non-legacy batteries), a unique QR code per item should be developed to avoid any deposit fraud.
Influence of DRS on collection rates
FEAD agrees that evidence remains limited. The consultants explicitly acknowledge that the effect of a battery DRS on collection rates could not yet be quantified in the study. The Feldbach pilot and Latvian experience are therefore particularly important. They suggest the following causal chain:
meaningful incentive + simple and accessible return infrastructure + clear consumer communication → increased willingness to return batteries → fewer batteries entering incorrect streams
While FEAD remains cautious against directly transferring beverage-DRS collection rates to batteries because batteries have longer lifetimes, much greater product heterogeneity, embedded applications and distinct safety requirements, the experience with beverage containers nevertheless demonstrates the effectiveness of a clear financial return incentive in changing consumer behaviour and improving separate collection. The Commission’s latest reporting under the Single-Use Plastics Directive shows that 10 of the 12 reporting countries that had already reached the 77% separate collection target for SUP beverage bottles in 2022 had a DRS in place, while six EU Member States had already exceeded the 90% target. This provides a strong indication that, when combined with convenient and accessible return infrastructure, a financial incentive can help deliver very high collection rates. A battery DRS should therefore build on this behavioural principle, while adapting its design to the specific characteristics and safety requirements of batteries.
Conclusion
FEAD considers that a well-designed battery DRS can become an important additional tool to prevent fires, reduce battery misplacement and strengthen separate collection. To be effective, it should cover all portable and LMT batteries, accept legacy batteries from the outset, build on existing collection networks and combine simple consumer incentives with robust safety and anti-fraud requirements. The objective should remain clear: keep batteries out of residual and other incorrect waste streams, before they become a fire risk for waste workers and facilities.
FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be