FEAD’s position on Batteries and Waste Batteries
FEAD, the European Waste Management Association, welcomes the European Commission’s proposal for a Regulation on batteries and waste batteries, fully in line with the Green Deal and the new Circular Economy Action Plan.
From a waste management perspective, FEAD is convinced this proposal is following the right course of action to achieve the circular economy with more and more ambitious targets in terms of quantity and quality.
Having a strong battery value chain is of strategic value and importance for Europe as well as for our industry. Recycling in a safe manner is an important activity in this value chain, from an economic and resource point of view.
In the following, FEAD presents its comments to the main important points of the Commission’s proposal:
- Lack of a mandatory deposit refund system
Incorrectly disposed of Li batteries pose a high risk to people and the environment. It is necessary to return 100% Li batteries from a wide variety of waste streams to the battery collection
This can only be achieved through a mandatory return for particularly critical material flows, in addition to a high collection rate for all device batteries.
- Mandatory recycled content
We welcome the introduction of an EU-wide roll out of mandatory recycled content.
However, the effective functioning of a circular economy requires mandatory recycled content to apply to all kind of batteries, including portable batteries, as well as higher levels of recycled content in new batteries
FEAD calls for an earlier determination of the methodology for the calculation and verification of recycled content to be able to adapt recovery processes accordingly
- Increased recycling and recovery targets
We welcome ambitious recycling efficiency and material recovery targets. On the proposal, we consider that targets for recycling efficiency are very high and may be difficult to achieve. Their achievement depends upon the rules for calculation and verification. For their determination, FEAD stresses that a differentiated approach is needed between portable batteries and all other categories of batteries, and also different chemical types of batteries
FEAD reminds that it is also necessary to establish a performant data gathering including the quality of recycling to create a level-playing field among recyclers in Europe. Low carbon footprint recovery processes should be supported
- Ensuring higher collection
FEAD welcomes the increase of portable battery collection targets. However, for achieving proper handling and correct disposal of batteries, higher collection targets of 80% for all types of batteries are needed, excepting for automotive batteries for which collection targets of 100% should apply. In a context of a constantly growing market for batteries powering light means of transport, FEAD urges the European legislator to include those batteries into the same collection targets as portable batteries as soon as possible
- Eco-design, marking and hazardous substances
EEE that can be operated on batteries must be designed in such a way that waste from them can be removed easily without tools by end users only, discharged without prior pack-disassembly and can ensure easy access to a hole for the fire-hose
Uniform marking of devices helps consumers use and handle correctly the devices and accumulators, to safely remove batteries and to ensure a proper disposal. On labelling, FEAD supports the setting up of colour coding for batteries to facilitate their sorting and collection
- EPR schemes
FEAD stresses the necessity to take into consideration the existing and successful B2B schemes/contracts that provide for collection, sorting, treatment and recycling. The extension of EPR schemes remain a tool for waste flows that are more difficult to capture, for instance originating from HHs. Collecting and recycling industrial batteries should remain under open market rules, which have proven to be efficient in delivering optimized investments and services
- Enforcing the control of illegal movements of battery waste
FEAD calls for an effective control and enforcement mechanism for the exports of used batteries to avoid illegal shipments
- Responsibility for sales via online marketplaces
FEAD welcomes the requirements for distributors to provide end-of-life information on batteries through their online marketplaces. But this does not solve the problem of uncovered costs of the EPR scheme on batteries. To address this free-rider problem, a level playing field must be restored between online marketplaces and stationary retailers in the EU. The same rules must apply to producers, distributors, online marketplaces or fulfilment companies as to stationary retailers.