New EU Battery Regulation Changes the Market – Eucobat Makes Finnish Producers’ Voice Heard in Brussels

Eucobat is a collaboration and advocacy organisation of European battery producers in Brussels. During his visit to Finland, Secretary General Eric Ruyters opened the association’s activities from the perspective of Recser’s producers. How does a Finnish battery producer benefit from Recser’s Eucobat membership? 

In Finland, the recycling of batteries is organised by Recser Ltd, a non-profit producer responsibility organisation. It represents more than 1000 companies that import, manufacture or distant sell batteries of different sizes, and chemistries, to Finland. In different EU countries, the collection schemes for batteries are managed by the respective national associations.  

The new EU Battery Regulation introduces significant changes to the battery industry. Unlike the previous legislation based on a directive, the Batteries Regulation covers the whole lifecycle of batteries and has therefore introduced new collection and recycling requirements for producers.  

As EU regulations apply uniformly in all Member States, the challenges faced by producer responsibility organisations in implementing the Regulation are similar regardless of the country. This has led to closer collaboration between operators in Europe.  

– The Battery Regulation has brought a big change to Eucobat’s operations. Our association now has a dedicated office, in support of the members, says Eric Ruyters.   

– We have doubled the team! This means that, instead of one person we are now two. We have a dedicated office of two people, Zina Nazarenko recently joined, she is the Relation and Development Director responsible for public affairs and members, he continues in a good mood.  

Eucobat, the European Association of National Collection Schemes for all waste Batteries, was established in 2012. It has 30 member organisations from 24 countries. The members are producer associations that run national collection schemes in different EU countries. Many of the member organisations were established 20-25 years ago, so they have existed for longer than Eucobat.  

European Colleagues Supporting Each Other  

Recser and other European organisations are supporting battery producers with the changes required by the new obligations.   

– When a new regulation comes into force, the implementation is not like you turn on a switch of light and it is implemented, Ruyters illustrates.  

Eucobat enables the sharing of experiences and information. For example, the Eucobat Community Platform facilitates direct questions to representatives of member organisations in other countries.  

Liisa-Marie Stenbäck, Managing Director of Recser Ltd, describes the employees of Eucobat member organisations as colleagues with whom to brainstorm, develop activities and share best practices. She says this is important because most producer responsibility organisations have small teams. 

– Sometimes it happens that you haven’t even had time to think about the whole issue yet, while someone else has already solved it, says Ruyters, describing the collaboration between Eucobat member organisations.  

– We are non-profit organisations, and collaboration is an important strength. Producer responsibility organisations do not compete. Recser is responsible for collection in Finland, not, say, in Spain, he continues. 

Producers’ Voice Make an Impact

Another role of Eucobat is to act as the voice of its members in Brussels. EU bodies are currently advancing the implementation of the Battery Regulation.  

– In Brussels, one voice would not necessarily be heard, but by organising ourselves as a group, we have been able to be part of the formulation of the regulation from the start, says Ruyters.  

– Influencing in Brussels also requires an understanding of EU policymaking, he continues.  

In advocacy, collaboration between Eucobat member organisations goes far beyond sharing their own experiences. Members organise themselves in working groups to form a joint position. Eucobat’s role is to take that forward. 

– The position is then not only just Recser’s position but also other Eucobat members’ position. This makes it stronger. 

– Joint positions are also important because many Finnish producers are active in other EU countries. In this case, it is good to share a common vision with producer responsibility organisations in these countries, says Ruyters. 

In line with the EU’s political decision-making system, the positions that Eucobat takes forward to the European Commission and other bodies also reach decision-makers in Finland and other national governments.  

– There are multiple ways to make the voice of the producer heard. This is another reason why you should join Recser, says Ruyters. 

Eucobat’s Work is Reflected in the Regulation

The work of Eucobat and the producer responsibility organisations on the new Battery Regulation started in 2019 with the first consultations. The advocacy work of the past years is now reflected in the formulation of the Regulation in favour of producers. The main changes concern the classification of batteries and the way collection targets are calculated.  

The Regulation now divides batteries into five categories: Portable batteries, Batteries for light means of transport (LMT), Automotive batteries, Industrial batteries and Traction batteries for electric vehicles. This classification is crucial as the Regulation obliges producers to collect and recycle decommissioned batteries in their respective categories.  

The Light Means of Transport category is a completely new addition to the legislation. Originally, electric bicycles and scooters were only supposed to be a sub-category of portable and small batteries. As LMT has grown into a very significant category in terms of numbers, Eucobat started to promote the joint position of the producer organisations of a separate category in the EU decision-making bodies. As a result of advocacy, this goal was achieved. 

The calculation methodology for collection targets in the Battery Regulation is another important point where the work of producer responsibility organisations and Eucobat is reflected. The calculation methodology will be based on the so-called “Available for collection” principle. It includes the idea that producers want to collect more but can only collect what is available. 

This is a significant improvement on the current model, where the collection obligation is calculated as a three-year average of the quantity that the producer has put on the market.   

– Alkaline batteries can have a lifecycle of five years. It is good that we do not need to innovate batteries that last only three years! That would have been completely against the spirit of the Green Deal, Ruyters chuckles. 

The Regulation is part of a major EU project, the European Green Deal strategy. The programme represents a new form of regulation emphasizing the products’ entire lifecycle and aiming to extend it by reusing materials. The aim of the programme is to move towards a circular economy. 

Tackling the Challenge of Free Riders

“Free ridership”, or the disregard of producer obligations, has been a much-discussed issue in Finland, says Stenbäck. The subject is also discussed in other EU countries.  

– It has been a problem, and it will continue to be a problem. However, the regulation will help to meet this challenge. Anyone who puts a battery for the first time on the market is a producer and the producer is subject to the producer’s obligations, says Ruyters.  

According to the Battery Regulation, all producer responsibility organisations must be recognised by a national supervisory authority and all producers must belong to these organisations. In this way, all operators will be registered. Eucobat will closely monitor the implementation of this requirement and will inform the European Commission at the Implementation Monitoring Meetings. 

But monitoring also requires accountability from national governments.   

– The shortage of staff in the supervisory authorities is an issue in every country. Most have recruited additional staff to carry out the tasks required by the Regulation, says Ruyters, illustrating the practical implementation of controls.  

Repurposing is an Opportunity for Pioneers 

– The new battery regulation brings not only challenges but also opportunities. Repurposing, for example, is an opportunity brought by the regulation, says Ruyters. 

– With the battery directive the collected waste batteries could only be recycled. Now, with the new Battery Regulation, the collected waste batteries can be re-used in a second-life solution. For example, collected waste LMT and /or EV batteries of electronic vehicles can have longer lifecycle when repurposed to industrial energy storage solutions, he continues.

The reuse of materials is one of the key requirements of the Regulation. Collected, decommissioned batteries are no longer seen only as waste but as raw materials to be repurposed. The market dynamics will change as the mixing requirement of the Regulation will increase the demand for different raw materials.  

Advocacy Continues for the Potential of the Battery Pass

The Battery Regulation includes a requirement for a new digital Battery Passport, an electronic record that comes with the battery and provides information on it. The Battery Passport is due to be introduced in February 2027 for Large industrial batteries, LMTs and Electric vehicle traction batteries. 

Eucobat is working to ensure that the passport guidelines include labelling requirements that benefit producers. The Commission is currently working on complementary regulations for battery passports.   

– The Battery Passport would be enormously beneficial if it could provide information on the the battery’s ingredients, manufacturer, battery category, and lifecycle stage. This would bring transparency to the market, says Ruyters, describing Eucobat’s objectives. 

The work for European battery producers will therefore continue at Eucobat with a dedicated small team and with the strength of the collaboration between active producer responsibility organisations. 

Eric Ruyters

EUCOBAT is the European association of not-for-profit collection schemes for waste batteries. EUCOBAT members strive for a better environment by collecting ever more used batteries and by recycling them ever better. EUCOBAT members ensure to organize the collection, repurposing, and recycling of used batteries as easily and efficiently as possible. 

In September 2020, Eric joined EUCOBAT, and supported the Policy Working Group of EUCOBAT on public affairs and strategic activities. Since he started at EUCOBAT the new Battery Regulation has been published and he has been fully involved in the process of the new Battery Regulation, both on an European level with EUCOBAT and EU Member States and on a national level as director of Stichting Batterijen, the PRO for portable batteries and director of Stichting EPAC, the PRO for e-bikes batteries in the Netherlands. 

Before joining EUCOBAT and the national PRO, Eric has a long industrial experience in the field of Consumer Electronics with Canon as European Sales Director and as Country Director of the Netherlands.

In the field of batteries, Eric was General Manager of Varta Consumer Batteries Benelux, in which he also was chairman of the board at Stichting Batterijen in the Netherlands, and director of the board of Bebat in Belgium. 

Since November 2023 Eric has been appointed the Secretary General of EUCOBAT to support all their members across Europe with the implementation of the new Battery Regulation.