EPBA’s position on the Commission’s proposal for a Batteries Regulation
EPBA welcomes the European Commission’s proposal to modernise the legislative framework for batteries and waste batteries which promotes the placing on the EU market of more sustainable and safer products throughout their entire life cycle supporting thus the European Green Deal ambitions.
Here is our position on the main points of the text published in December 2020:
EPBA continues advocating strongly for a collection target based on what is available for collection which takes into account the longer than 3 years life span of a cell in the EU market as well as the batteries exported outside the EU in (W)EEE (more details about this topic here)
EPR – modulated fees: The durability and performance requirements (art. 9 of the proposal) will be a more effective tool to increase the quality, sustainability and safety of portable batteries placed on the EU market than the use of modulated fees.
Pragmatic approach to labeling avoiding duplication of information: being mindful of the limited space available on both the product and packaging as well as the much needed clarity for consumers, EPBA supports simplifying information to be put on the label/packaging and using the QR code for more details.
Definitions reflecting the actual market: the definition of portable batteries of general use should be limited to the most common sizes: AA, AAA, C, D & 9 Volt for which there is also a rechargeable equivalent
Simplify the conformity assessment by limiting it to the main five sizes of portable batteries, reducing this way unnecessary administrative burden. Products are also subject to frequent modifications which do not always impact on the functionality. Minor modifications should hence not require a complete new assessment.
Visible fee fostering increased consumer awareness and involvement on the collection of waste batteries: EPBA is very pleased this proposal allows for the cost for the EPR obligations, among which the collection of waste batteries, to be shown separately at the point of sale to the end-user.
High performing, long lasting and safe portable batteries in the EU market: EPBA welcomes the proposal to set quality standards for portable batteries and remains available to contribute with its expertise about performance, durability as well as sustainability parameters for the future standard.