EUROBAT Position: Recycling efficiency methodology

EUROBAT thanks the Commission for the opportunity to share feedback on the draft Annex to the Delegated Regulation supplementing the Batteries Regulation to establish the methodology for the calculation and verification of the rates for recycling efficiency and recovery of materials of waste batteries, and the format of the documentation, as discussed during the expert group meeting of 21 March 2024.

In this position paper, EUROBAT would like to raise two issues on the draft delegated act: one linked with the proposed formula to calculate the rate of recycling efficiency, and how to define what should be accounted as input and output fractions (1), and the other linked with the absence of a definition of “first recycler” in the draft delegated act (2).