EUROBAT Position: Update of the EU List of Waste for battery-related codes

EUROBAT thanks the Commission for the opportunity to comment on the draft Annex to the upcoming delegated act on the update of the list of wastes, as presented during the expert group on waste meeting of 8 May 2024. While we support ending the fragmentation of battery-related waste codes in the EU, we are concerned by the complexity of the draft new codes and their practical applicability.

In our position paper we propose to resolve the issue by establishing a unified code for the manufacturing waste of lithium-ion batteries and a single code for waste lithium-ion batteries. Indeed, waste treatment companies might not have a certain code on their license and may use another code instead. Embracing an easy-to-use approach will streamline shipments within the EU.