Landbell Group company European Recycling Platform (ERP) contributed to the public consultation, which ended on 1 March, by submitting a position paper.
In general, ERP welcomes the Commission’s proposal and commends the proposal’s ambition to reflect both the latest market and technological developments, and the latest changes to general waste legislation.
However, ERP suggests a few amendments to ensure that the new Regulation can fully deliver on its objectives, including:
- a specification of the definitions of “portable batteries” and “industrial batteries” to avoid overlaps with other battery types,
- a more realistic approach to the collection targets for waste portable batteries, taking into account aspects like the increasing lifetime of batteries and exports,
- a requirement on final users to hand over their waste batteries to producers or producer responsibility organisations to ensure that all batteries available for collection find their way to the actors held responsible for collection,
- effective enforcement measures to ensure compliance and combat free riding.
The European Parliament and the Council of the European Union will now discuss the Commission’s proposal. ERP will contribute its extensive experience in the field of battery take-back to the further consultations.