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Web: www.epba-europe.org
EPBA
EUROPEAN
P ORTAB LE
B A T T E R Y
ASSOCIATION
SUGGESTED FOR MAT FOR WRITING TO DG ENV:
N.B. This submission must be received by the European Commission DG ENVI, by 28th April latest. We
suggest that you copy this submission to your relevant national ministry dealing with the battery directive
(usually the Environment or Industry Ministry). Good communication with your national government will
be vital for the next two years as the battery directive goes first to the European Parliament and then to be
discussed in the Council of (national) Ministers.
Your submission will be placed on the DG ENV web site UNLESS you do not want it to be.
___________________________________________________________________________________
“OFFICIAL STATEMENT ON THE CONSULTATION OF EUROPEAN COMMISSION DG ENV ON
ON BATTERY DIRECTIVE,
FROM national battery association X.
Date:
Association X hereby submits comments on the selected policy options related to the revision of existing
battery directives, as posted on the DG ENVI web site on February 25th 2003.
Association X is the national battery association for ……..(mention your country). Our mission is to …….
We cover …..% of the national battery market. We enjoy relations with national government (mention
where) , sectoral trade associations (mention), consumer groups (mention) and leaders of industry.
Association X is an affiliate member of the European Portable Battery Association
Association X welcomes the initiative of DG ENVI to consult stakeholders requesting for input on
the Extended Impact Assessment and wishes to play an active role in the subsequent steps of the
legislative procedure in order to ensure the sustainable regulation of the battery industry in
(mention your country).
Collection and recycling targets for portable batteries:
In assessing how best to approach the questions raised we have taken the principle of producer
responsibility, the introduction of a voluntary agreement and the use of alternative calculation
methods into account.
Also, in order to best address the economic, social and environmental consequences of each
option, we have split the collection requirement into its divers stages.
EPBA/
1
Collection principle:
Considerations: NBA to describe the bases of the system in place in your Member State (if you have one),
how long it has been in operation, which battery systems it covers and the advantages and disadvantages of
such a system.
Use the EPBA considerations as set out.
Most sustainable option: Use the EPBA option as set out and describe how it can be applied to your
national system.
Collection responsibility:
Considerations: NBA to describe national system, if applicable. Add item on ease of use for the consumer
and how this might be improved.
Most sustainable option: see EPBA document ensuring that all involved in the battery chain cover their
own responsibility.
Collection method: NBA to mention other products collected separately (not with other waste or through
a household waste stream) in that country.
Considerations: the geography and climate of your country will be important here.
Most sustainable option: the EPBA advocates collection of batteries with other recyclable wastes
such as WEEE, packaging or glass - where possible.
Collection targets: NBA to describe national system. This can be maintained if favourable to industry “favourable” is as set out in the most sustainable option.
Considerations: national culture and habits are an important component of the calculation of targets.
Also, the imposition of a set target across the EU needs to take these elements into account as well as the age
and efficiency of the collection system in place, if there is one. Consumer behaviour is key to reaching a
specified collection target.
Most sustainable option: “EPBA recommends an indicative AND differentiated collection target
per member state based on weight per inhabitant. The EPBA advocates the range of between 50
and 130 gr/inhabitant per Member State taking collection scheme age and efficiency into
account”.
Recycling and target setting:
Considerations: NBA to describe advantages and disadvantages of national system. Principle should be
stated that recycling targets should be measurable and verifiable and based on the availability and technical
capabilities of technology.
Most sustainable option: “Adoption of a system if accreditation using BATNEEC principles, for
battery recycling companies”.
2
EPBA/GPG / DAG meetings / NBA letter template_040403_final
FINANCING of system:
Considerations: NBA to describe national system. However, an important principle needs to be
repeated, “in assessing the best financing system, it is necessary to distribute the total cost among
all parties involved in the chain”. Also, it worth mentioning that “stringent control mechanisms
should be put in place by Member States to avoid the occurrence of free-riders who do not
participate in, nor finance the collection and recycling scheme”.
Most sustainable option: The principle of shared responsibility is a necessary inclusion to any
financing mechanism.
3
EPBA/GPG / DAG meetings / NBA letter template_040403_final