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Targeted amendment of the European List of Waste as regards waste batteries and wastes from their treatment

Environment

To help manage waste, the European List of Waste provides common terminology for classifying waste across the EU, including hazardous waste. The Commission intends to revise this list to take account of new battery chemistries and rapidly evolving manufacturing and recycling processes. Its objective is to improve the identification, monitoring and traceability of the different waste streams and bring certainty on their status as hazardous / non-hazardous waste.

Links

Public consultation

ID: 14016

Lobbying Activity

18 responses

Transport and Environment urges EU ban on battery waste exports

Transport and Environment (European Federation for Transport and Environment), 7 Nov 2024

T&E supports classifying all battery waste as hazardous to prevent critical minerals from leaving the Union. They advocate for an export ban and stronger enforcement at borders.
This ensures a stable supply of materials to scale up European recycling capacity.
Non-OECD countries and facilities with low environmental standards lose access to valuable waste.

Auto Industry Seeks Simpler EU Battery Waste Transport Rules

Association des Constructeurs Européens d'Automobiles, 8 Nov 2024

ACEA requests a Europe-wide standardization and simplification for transporting waste batteries across borders. They seek a 24-month transition period for implementing new waste codes. The organization argues current fragmented national rules create excessive administrative work and transportation costs.
This would reduce their compliance burden and lower transportation costs for recycling operations.
Environmental regulators lose stricter oversight of hazardous battery waste movement across borders.

Eurometaux urges swift adoption of new battery waste codes

EUROMETAUX, 8 Nov 2024

The group wants the EU to quickly adopt new codes for batteries and black mass. They request harmonized rules and customs alignment to prevent materials from leaving Europe.
This ensures valuable strategic materials stay in Europe for domestic recycling.
Non-EU processors lose access to critical materials currently leaked from European markets.

EuRIC urges three-year delay for new battery waste codes

European Recycling Industries' Confederation, 8 Nov 2024

EuRIC requests a 36-month transition period to update facility permits for handling waste. They argue that classification should focus on product properties rather than chemical ingredients. They also advocate for fast-track notification procedures to streamline battery transport within the EU.
Recyclers avoid immediate operational disruptions and the high costs of permit updates.
Environmental monitoring and waste traceability are delayed by the requested transition periods.

Umicore urges strict battery waste classification and export limits

Umicore, 31 Oct 2024

Umicore supports classifying all battery waste as hazardous and proposes a temporary export ban to prevent materials from leaving Europe. They also call for a single market with fast-track notification procedures for shipping waste between member states.
This would secure a supply of secondary raw materials while reducing cross-border administrative burdens.
Foreign recycling companies would lose access to battery waste currently exported from the European market.

Northvolt urges rapid adoption of battery waste classification rules

Northvolt, 1 Nov 2024

Northvolt welcomes the draft decision and calls for its quick adoption. They argue it creates a uniform framework for handling waste batteries across the EU.
A streamlined hazard classification system reduces regulatory complexity for their battery recycling operations.

FEAD demands 24-month transition for hazardous battery waste classification

FEAD, 8 Nov 2024

FEAD calls for a 24-month transition period for implementing new waste codes. They also propose merging overlapping battery classifications to avoid operational confusion and high costs.
This would provide more time for complex waste permit amendments and necessary infrastructure investments.
Regulators lose granular data tracking of specific battery chemistries through merged waste codes.

Galp urges broader definitions for battery manufacturing and recycling waste

GALP ENERGIA SGPS, SA, 8 Nov 2024

Galp recommends including defective battery cells and materials like electrolyte waste in the manufacturing waste lists. They also emphasize the need for a precise definition of materials generated during recycling to ensure treatment consistency.
Detailed waste categories would lower legal ambiguity and improve efficiency in Galp's recycling operations.
Regulators and other recyclers lose when vague definitions lead to inconsistent interpretations across Europe.

RECHARGE urges clearer waste definitions to support European battery recycling

RECHARGE aisbl, 8 Nov 2024

The association recommends adding a specific definition for black mass to the waste list. They propose fast-track shipping procedures for hazardous waste sent to approved recycling centers.
A stable legal framework will help companies secure long-term investments in battery recycling.
International exporters lose profits as stricter codes prevent valuable waste from leaving Europe.

EUROBAT warns complex waste codes will stifle battery recycling

Association of European Automotive and Industrial Battery Manufacturers, 8 Nov 2024

EUROBAT requests a simpler, easy-to-use list with fewer waste codes. They argue the current proposal is too technical and complex for practical application.
Streamlined codes would lower administrative burdens and prevent licensing delays.
Regulators may lose granular data required for precise waste tracking.

Czech Chamber opposes hazardous waste label for zinc batteries

Hospodářská komora České republiky, 5 Nov 2024

The organization opposes labeling zinc batteries as hazardous and requests an impact assessment on raw material goals. They propose delaying these changes until mid-2026 to align with shipping regulations.
This would prevent administrative delays and ensure recycling projects meet strict permitting deadlines.
Retailers and schools might stop collecting batteries due to the psychological stigma of hazardous labels.

Hazardous Waste Europe seeks new codes for battery solvents

Hazardous Waste Europe, 8 Nov 2024

HWE proposes adding four new waste codes for solvents used in battery production. They want these chemicals recycled as raw materials rather than being discarded.
Specific codes would help the industry direct valuable materials to recovery facilities.
Traditional disposal firms lose business as solvents are diverted toward specialized recovery facilities.

Consultation response

European Union for Responsible Incineration and Treatment of Special Waste, 8 Nov 2024

Eurits supports the Commissions ongoing actions to improve and revise the European List of Waste (LoW) to reflect advancements in waste treatment processes. However, we believe the proposed amendments represent a missed opportunity to better align Regulation (EU) 2019/1021 on Persistent Organic…

Consultation response

Contemporary Amperex Technology Hungary, 7 Nov 2024

The classification of black mass should be based on its chemistries; black mass from LFP batteries should be considered as non-hazardous. intermediate fraction from the thermal/mechanical treatment of waste lithium-based batteries and lithium-based battery manufacturing waste containing a mixture…

Consultation response

Stena Recycling Holding Ab, 8 Nov 2024

Stena Metall AB welcomes the initiative to add waste codes for battery waste since there has been some confusion and different interpretations regarding this waste in the member states, which has been hindering an efficient recycling. We are however, not in favor of the proposed absolute hazardous…

Consultation response

EUCOBAT, 8 Nov 2024

EUCOBAT, the European association of national collection schemes for batteries, thanks the European Commission for the opportunity to provide feedback on the amendment of the European List of Waste addressing waste batteries and battery-related wastes. EUCOBAT supports the findings of the JRCs…

Consultation response

Hungarian Waste Management Federation, 8 Nov 2024

We welcome the opportunity to comment on the draft EU Decision amending Decision 2000/532/EC as regards an update of the list of waste in relation to battery-related waste. We would like to make the following proposals: 1) Speeding up waste shipment and permitting procedures We would like to stress…

Consultation response

Stowarzyszenie Forum Recyklingu Samochodów, 8 Nov 2024

W imieniu Członków Stowarzyszenia Forum Recyklingu Samochodów - FORS, chciałbym podkreślić, że dodanie nowych kodów odpadów baterii jest bardzo potrzebne do prawidłowego funkcjonowania stacji demontażu oraz zakładów przetwarzania baterii w całej Europie. Do stacji demontażu coraz częściej trafiają…