On 19 March 2021, the Association for Take-back and Recycling of Waste Electrical and Electronic Equipment (VERE e.V.) submitted its opinion on the draft Regulation of the European Parliament and of the Council on batteries and waste batteries (EU Battery Regulation) to the Federal Ministry for the Environment (BMU). At present, VERE has about 4,000 association members, of which about 1,500 are legally listed as manufacturers of batteries in the battery registers of the German Federal Environment Agency or the EAR Foundation (German WEEE and batteries registration board).
Basically, VERE perceives the present draft of the Battery Regulation as a massive overtaxing of market players in view of an overambitious time schedule. It is not discernible from VERE's point of view why such far-reaching adjustments and new introductions should be introduced in such a short time. According to VERE, most market players will not be able to implement and comply with so many requirements at such short notice. Implementation as part of a longer-term/multi-year-phased plan seems more appropriate to VERE.
Even if the long-term objective of the Battery Regulation basically appears to be plausible and reasonable, the multitude of points that are open to interpretation as well as the institutions that still have to be created for the implementation and enforcement of the Regulation in such a brief period of time seem to be unrealistic from VERE's perspective. VERE urgently recommends taking the realities of the market and the possibilities of the vast majority of today's players into account.
In particular, VERE believes that smaller-scale manufacturers and those for whom batteries or rechargeable batteries are not the primary object of sale but an add-on for the functional delivery of a device will need to decide at very short notice whether they can still include batteries in shipments at all. VERE perceives the danger that the flexibility in the choice of procurement sources for batteries will be confined to those manufacturers who are prepared to offer “ex works” batteries that are compliant and registered in conformity with the Battery Regulation. In particular, large-scale industry, which already holds a dominant position in various segments today, will probably endorse and welcome the Battery Regulation. According to VERE, this segment will be the actual beneficiary of this regulation.
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