The Battery Directive, published in the Official Journal of 26 September 2006, reiterates the principle of producer responsibility for collecting and recycling waste batteries. It does not however detail how producers should comply with this legal requirement. The Directive only states that Member States shall ensure that appropriate collection schemes are in place for waste portable batteries (Art 8). This requirement has to be read together with the obligation for producers to finance any net costs arising from the collection, treatment and recycling of all collected waste portable batteries (Art. 16). The Directive does not give neither information nor guidance on how a compliance organization should be set up and how it should operate. It only specifies in an explanatory recital (18) that batteries can be collected (1) individually, (2) by way of national battery collection schemes or (3) together with the WEEE collection schemes. Although not specified by the Directive, regardless which option will be taken at national level, it is important that the industry takes the initiative to ensure a workable and cost-efficient CO. Binding EU minimum performance requirements for EPR would considerably improve the achievement of collection targets while ensuring a level playing field for all EPR schemes (regardless of their ownership structure) and promote a viable market for secondary raw materials.
See also joint position paper on minimum requirements for EPR schemes:
Portable battery collection is very complex and is subject to a wide variety of parameters such as: consumer awareness, legal frameworks, density of the collection points, variety of collection streams and the need to ensure that every actor in the waste collection process takes up its responsibility. The way these are implemented differ highly from one member state to another one.