The European Recycling Industries’ Confederation (EuRIC) endorses the ambitious measures adopted by the ENVI Committee of the European Parliament which will govern the entire battery life cycle. These measures are of an utmost importance for the transition to a circular and climate-neutral economy. Such a level of ambition shall be kept as EU institutions are entering the final stages of the negotiations.

We strongly welcome the amendments on recycled content targets (Article 8) which are addressed to more battery types than initially proposed and are crucial to further closing the loop in the battery value chain. As consistently stressed by EuRIC, European recyclers strongly support mandatory recycled content targets for battery production as an efficient and necessary policy instrument to increase the demand for high quality materials coming from recycling and provide the predictability needed to long term investments and capacity-building in Europe along the value chain.

Actors already building a circular economy for batteries in Europe, i.e., repairers, refurbishers and recyclers, alongside environmental NGOs, call on the European Commission, Parliament and Council to adopt ambitious requirements in the Battery Regulation to enable battery removal, replacement and repair for consumer electronics and LEVs.

Removable, replaceable, and repairable batteries are an essential element of the battery regulation in order to support value retention and circularity, reduce EU dependency on critical raw materials, reduce e-waste and unnecessary consumption, as well as supporting worker safety and fire prevention.

EuRIC calls upon policy makers to set ambitious removability, replaceability and repairability requirements in Article 11 of the battery regulation:

Scope: the scope for these removability requirements should cover all consumer electronics. Light means of transport (e.g., e-bikes and e-scooters) should also be included in the scope. Removal and replacement for all: battery removal and replacement should be enabled for both independent professionals and end users. Enabling removal and replacement by citizens is essential for battery recovery and extending the life of electronics. Battery removal should be possible with no tools at all, or commonly available tools (i.e., with respect to EN 45554:2020).

Battery repair and repurposing for professional repairers: as well as removability and replaceability, battery repair should be enabled for independent professionals. The Commission is encouraged to start a standardisation process for cell level repair and repurposing.

Batteries as spare parts: quality battery packs should be available to end users as spare parts for at least the expected lifetime of the device. The components of the battery packs (e.g., cells, casing,board/BMS) should be available to independent professionals. Clear replacement and repair instructions should be freely available to end users and independent operators respectively to ensure safe battery management.

Software: battery software should not be a barrier to battery replacement or repair. Updates and serialisation should not prevent or discourage replacement by end-users, and independent operators should be able to manage the BMS to restore batteries they repair or repurpose.

Derogations: it is foreseeable that there are justifiable cases for exemptions for these requirements (e.g.,for medical devices) however any derogation should not present a loophole for manufacturers. Overall, single use, unrecoverable applications such as “printed batteries” should be reserved for essential applications.

The Waste Shipment Regulation (WSR) is a key piece of legislation in the move towards circular value chains. Burdensome procedures and lack of harmonisation rooted in the current regulation give an edge to linear value-chains, instead of boosting waste shipment for recycling and the marketing of raw materials from recycling (RMR).

However, the proposals released today by the European Commission pose major problems that will jeopardise Europe’s circular economy ambitions.

European recyclers entirely support the objective to better tackle illegal waste trade and exports of unprocessed waste to countries lacking the infrastructure for proper treatment. Such exports not only threaten human health and the environmental, they also are a major economic loss for Europe’s recycling industry.

Yet, by failing to distinguish between trash and RMR that meet strict quality specifications, the proposal falls short of levelling the playing field with extracted raw materials, which are not subject to any such constraints in EU law.

“Free, fair and sustainable trade of RMR is absolutely essential to boost high-quality recycling in Europe and ensure the recycling industry remains competitive,” says Emmanuel KATRAKIS, Secretary General of EuRIC.

“Europe’s recycling industry is powered by SMEs and large companies, who directly employ over hundreds of thousands of Europeans, and indirectly many more. As stressed in the recent letter signed by 300 European national recycling federations and companies, subjecting RMR - which are still classified as non-hazardous waste - to export restrictions will, in the absence of secured end-markets for circular materials in the EU, pose a vital threat to European recyclers, be them SMEs or large multinational companies, and undermine the creation of green industrial jobs in Europe.”

“With only 12% of raw materials used by the EU’s industry coming from recycling, binding requirements to use RMR in industrial value chains are urgently needed to ensure the excess supply of RMR, that would remain captive in Europe under these proposals, don’t end up in landfills. In the Commission’s toolbox to boost the transition towards a circular economy, binding recycled content targets have proved to be the most efficient yet least utilised instrument, with the exception being for plastic packaging.”

EuRIC looks forward to working with the European Parliament and Council to better distinguish trash from RMR and ensure a fit-for-purpose regime applies to curb exports of problematic waste streams without closing frontiers to the most resource-efficient and carbon-neutral materials needed to achieve EU’s and global climate objectives.

EuRIC also looks forward to working with the co-legislators to further increase the ambition of proposed measures to ease intra-EU waste shipments for recovery and end-use in circular value chains, which are essential to achieve a well-functioning market of raw materials from recycling and level the playing field with extracted raw materials.

ETRMA and EuRIC are committed to support the European Commission in developing EU harmonized End of Waste (EoW) criteria.

The rubber supply chain is ready for the next step in the advancement and uptake of the recycling of ELT-derived Rubber.

This will secure that trade across European borders happens normally in equal conditions and with equivalent opportunities across borders, while reducing the administrative burdens associated with trading.

Since many regulations, like Declarations of Performance for construction products, or the REACH restriction of chemical substances only apply once the material has ceased to be waste, EU harmonized EoW criteria will also secure the material’s accountability for safety and quality criteria.

All this is of key importance to increase the uptake of ELT derived rubber in the manufacture of new rubber products for high-value end-use markets.

ETRMA and EURIC believe that securing a common starting point for end-of life tyres rubber to cease to be waste is essential to foster the circular economy in Europe. This can only be achieved with a European End-Of-Waste criteria, that is translated in a legal text, applicable in all Member States. This will add trust to the market, increase investors security and boost the research and development on innovative solutions of this valuable material.

Nearly 300 European national federations and companies from the recycling industry have issued a powerful warning to European Union leaders over the potentially disastrous effects of a blanket restriction on exports of Raw Materials from Recycling (RMR) in the upcoming Waste Shipment Regulation (WSR).

RMR are currently labelled as non-hazardous waste under EU law and would therefore be impacted by any regulation that issues a blanket ban on waste.

In fact, RMR are not waste but high-quality commodities with a green carbon footprint. They are materials recovered from old products that go into making new ones and as such are an essential component of Europe’s - and the international community’s - circular economy.

Addressed to the Executives of the European Commission, the European Parliament and the Slovenian Presidency of the Council, the letter calls for a clear distinction in the legal regime between “problematic waste streams” and RMR, meeting quality specifications.

While European recyclers entirely support restrictions on exporting unprocessed waste, like electronic waste and end-of-life cars, to places that lack infrastructure for proper treatment, RMR that can be used to substitute extracted raw materials should not be made subject to rules equivalent to export restrictions.

“RMR are intrinsically climate-friendly and circular materials, which are priced and traded globally as commodities. European recyclers are supplying quality materials to both the European industry and globally. Subjecting RMR - which are still classified as non-hazardous waste - to export restrictions will pose a vital threat to European recyclers, be them SMEs or large multinational companies, in the absence of secured end-markets for circular materials in the EU. They will result in massive green job cuts and put a lasting brake on the growth of one of the most dynamic industries in Europe, for no environmental gains. Worse still, with unhampered imports of extracted raw materials in Europe, the competitiveness of RMR will drop and thus the incentive to properly collect, recycle, and invest will be lost, putting at risk the ability to achieve present recycling targets set by legislation”, stressed Cinzia Vezzosi, President of EuRIC.

With only 12% of raw materials used coming from recycling, the EU’s industry remains mostly linear, as opposed to circular, the co-signatories urge the EU to ensure that:

1. Export restrictions foreseen in the revised WSR solely target problematic waste streams: a “one-size-fits-all” solution whereby no distinction is made between untreated problematic waste streams and RMR that can be used directly in circular value chains will run against the very objectives of the EU Green Deal;
2. Free and fair trade of RMR, which is essential to the competitiveness of the European recycling industry, is upheld: restricting exports of raw materials meeting quality specifications based on their waste classification will significantly impact the competitiveness of the European recycling industry;
3. A stable legislative framework with a proper classification for RMR and incentives is implemented to reward the environmental benefits of circular materials and mandate their use in products.