The Packaging and Packaging Waste Regulation (EU) 2025/40 establishes requirements on recyclability, minimum recycled content, reduction targets, and restrictions on certain packaging formats. It also includes obligations on labelling, reuse systems, and extended producer responsibility.

EPBA - Consumer Batteries Europe strongly supports the objective of reducing packaging waste and improving circularity across the European Union. At the same time, we believe in child safety and have asked for an exemption under Article 7 of the minimum amount of recycled plastic content for blister packaging covering LiCoin cells, as virgin plastic guarantees the child-safety nature of the packaging.

We also emphasise the need to ensure coherence between this legislation and the Batteries Regulation, particularly regarding labelling and information requirements, to avoid confusion for consumers.

We have raised concerns regarding Annex 5.1, as certain packaging-ban provisions may not reflect the practical realities of the portable battery sector. Portable batteries are often sold in multi-packs for emergency and household use, and banning such multi-packs goes against the nature of products often bought in bulk for longer periods of time.