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 study of 2024 to provide technical support to the preparation, implementation and accompanying measures related to the new Battery Regulation (EU) 2023/1542. EUCOBAT would like to share recommendations, among others, on: reconsider the intention to classify alkaline and zinc carbon batteries as hazardous waste, simplify the documentation process and administration burden, improve time necessary for the environment and competent authorities, implement the new codes in the new permits for the facilities across the EU, not to create additional administrative burden on having waste alkaline and zinc carbon batteries as hazardous waste, support a fast notification process. More details in the document attached.
Please find EUCOBAT recommendation on the calculation and verification methodology of rates for recycling efficiency and recovery of materials of waste batteries in the document attached.