Financing

The Commission might propose in the text of the revised Battery Directive that industry be entirely responsible for the financing and the organisation of collection. A study of five EPBA member companies shows that based on the above mentioned system and with a fixed collection rate of 75%, the costs of collection would rise up to EURO 5600 per tonne of batteries collected. One direct consequence for the consumer would be an increase in price of 54%.

Market actors (retailer, producer/importer) should have the opportunity to make their cost visible to the end-consumer in the same way as public actors (municipalities) make their cost visible to the citizen by waste taxes.

The EPBA disagrees with a deposit system, because any such system is not economically feasible and is impractical. There are many difficulties linked to the control of the system through the sales outlets and will add huge burden to the trade. Furthermore, it does not act as an incentive to collect batteries due to their long lifetime (3-15 years). Finally, the system is very open to fraudulent use.

Transparency of financing mechanisms is essential and therefore EPBA proposes that if the consumer is expected to pay the financial costs associated with collection, that costs be completely visible to the consumer at the point of sale.

EPBA proposes that a shared responsibility of collection is the most effective system. Austrian and German authorities have already implemented this type of operation successfully and it shows that costs can be reduced to EURO 1300 per tonne of batteries, providing a collection rate of 53%. EPBA wants to underline that legislation based on shared responsibility and with a collection target of between 50-130 g/inhabitant at a total cost target of EURO 1000 per tonne of batteries collected is possible and economically feasible for industry.