JUUL Labs UK Ltd
Juul Labs
Our mission is to transition the world's billion smokers away from combustible cigarettes, eliminate their use, and combat underage usage of our products.
ID: 607621632219-36
Lobbying Activity
Response to Modernising the EU’s batteries legislation
6 Jul 2020
JUUL Labs supports the European Commission’s goal to ensure a competitive, circular, sustainable and safe value chain for batteries placed on the EU market and welcome the opportunity to take part in this consultation.
From the onset, we would like to stress that any legislative proposal resulting from this consultation should be mindful of the variety of batteries on the EU market. One-size-fits-all approaches are not advisable given the diverse batteries portfolio, their manufacturing processes and final use. Any legislative requirements should be proportionate and should not go beyond the measures laid down in REACH, RoHS and EU Regulation 1103/2010.
When looking at Extended Producer Responsibility (EPR), we emphasize the need for a clear distinction between ‘re-use’ and ‘second-life’/’use’ batteries. The absence of a ‘re-use’ definition brings forward potential issues regarding second use EPR. In cases of batteries’ second use, responsibility and recycling obligations should be transferred. The original producer should only be responsible for the first use.
Any new legislative proposal should clarify the interaction between ‘take back programmes’ and EPR schemes. If a company sets up its own ‘take back programme’ (which is equivalent to an EPR scheme), it is unclear whether it also needs to pay for an EPR scheme. It is important that the Commission addresses the concerns around double payments and encourages companies to put forward take-back programmes which oversee both recycling and reuse.
We encourage the Commission to put forward common guidance with recommendations for manufacturers looking to maximise the battery’s life cycle. The Commission should encourage extending the cycle life of rechargeable batteries through consideration of design trade-offs like reduced charge voltage vs. energy density design targets and use of advanced charge algorithms that prolong cycle life and reduce swelling in Lithium polymer cells. In order to minimise waste of batteries and raw materials, the Commission should ensure that battery-containing products designed for single use do not contain rechargeable batteries.
The existing EU Batteries Directive and Regulation 1103/2010 support the development of a batteries’ framework, including information about the capacity of a battery, end of life care and how to safely remove them. We would welcome further clarification on the target recipient of this information in order to ensure a high level of safety. In certain cases, battery-removal instructions should only be provided to specialised and certified businesses, which are tasked with battery dismantlement. It is important that, when batteries are not intended to be removed, the dismantling information should clarify this for the end users. In addition, we recommend that user removable and replaceable batteries are avoided where possible in order to improve end user safety.
When looking at collection targets, we underlined the importance of putting forward a uniform set of EU standards similar to those in WEEE. In addition, collection targets should be linked to the different types of batteries.
We encourage greater transparency on local compliance scheme vendors’ processing of batteries, and guidance from the Commission on how businesses and manufacturers can retrieve the recycled materials.
When discussing responsible material sourcing and manufacturing, it is essential to ensure a high level of clarity in definitions and standards. In addition, the Commission should - as a means to achieve a high level of compliance - put forward guidelines on how stakeholders can comply with the requirements.
Lastly, we would like to stress the importance of consulting with stakeholders in the development of any follow-up legislation, particularly when looking at standards and labeling. This is important for efficiency and compliance, given the costs and time needed to adapt to new manufacturing, sourcing or processes requirements.
Read full responseMeeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)
29 Apr 2020 · The Tobacco Excise Directive