The European Portable Battery Association (EPBA) is the leading organisation representing the interests of primary and rechargeable portable battery manufacturers, industries using portable batteries in their products and distributors of portable batteries active within the European Union and beyond.

 EPBA welcomes the initiative from the Commission to further combat packaging waste and increase packaging circularity across the European Union. We believe that the proposal for the Packaging and Packaging Waste Regulation (PPWR) represents the most appropriate legislative tool to attain this goal. As such, we welcome the PPWR’s general principles of substantial packaging reduction and better circularity of raw materials.

 Furthermore, we are most appreciative that the Commission aims at strongly protecting the fluidity of its Single Market. We therefore strongly support:

 ·       Article 4, which stresses the importance of free movement of packaging across the EU;

 ·       Article 6‎ supporting the development of a harmonized definition of ‘recyclable packaging’ at EU level;

 ·       And the choice of a Regulation over a Directive which strengthens a uniform application of the provisions across Member States.

 We believe however that Article 11 presents certain elements of concern. Batteries’ marking is already subject to stringent regulation via the Batteries Regulation that will soon be enacted by the EU. We hence hope that the labeling requirements of the PPWR will not conflict with those from the Batteries Regulation. In particular, we hope that Article 11 paragraph 4 allowing for a grouped use of the QR code will be maintained as it would otherwise become too confusing for the consumer facing a multitude of different labels/QR codes on the packaging. In the same vein, we also hope that Article 11 paragraphs 7 and 8 will prohibit the excessive use of symbols and/or labels on the sustainability and EPR aspects of the packaging. We understand and wholeheartedly agree with new environmentally ambitious initiatives. However, these initiatives should be fully aligned so as to avoid multiple codes, logos or other labels requirements on our already very full packaging space.

 Labeling space on portable batteries packaging is indeed becoming more and more limited and we would like to use that space as much as possible to inform the consumer on the specific characteristics and correct use of our product, as often mandated by EU legislation and other international standardization bodies. Imposing the marking of other redundant icons/information would risk clouding the more essential safety-related instructions.

 Moreover, Article 26 paragraphs 12-13 are especially stringent and worrisome for the portable battery industry. These paragraphs oblige the industry to make use of fully re-usable materials for the transport of our products. We fear that this obligation might not be realistically attainable. To cite an example, pallets that are coming from outside the EU and imported into the EU could not be shipped back to their original destination to be re-used. We therefore ask here that pallets coming from outside the EU be exempted from the obligation to be re-usable.

 We are also concerned with the Article 22 bans in particular in conjunction with Annex 5.1. This latter annex would prohibit all products group-wrapped with plastic packaging for convenience reasons and would in essence ban all portable batteries plastic-packed together to make one unit of sale. This goes against the nature of our products which are most often sold in group as those serve as an essential fallback in any household to guarantee an emergency power reserve for safety or basic utilities. They are consequently often bought in bulk and preserved for longer periods of time. Additionally, more sales of single batteries as opposed to sales of packaging-efficient packs of several batteries will mean ‎more packaging waste. Moreover, we feel that the absence in Article 22 of scientific and/or researched and measurable criteria shaping the eventual Annex 5 list is dangerous and might pave the way to future arbitrary and unsubstantiated bans of certain products as per delegated acts foreseen in Article 22 paragraph 4. In conclusion, we ask that explicit criteria be used for establishing Annex 5 and that plastic wrappings could still be used for basic necessity products such as portable batteries.

 Finally, we believe that the PPWR has the potential to accelerate the transition towards a circular economy for all packaging. As this necessitates major adaptations for the industry which can easily run in years, we remain confident that the Commission will take our remarks into due consideration.

About EPBA

The European Portable Battery Association (EPBA) is the leading organisation representing the interests of primary and rechargeable portable battery manufacturers, those industries using portable batteries in their products and distributors of portable batteries active within the European Union, and beyond.

 www.epbaeurope.net

Contact:

Carole Bachmann, Secretary General, EPBA, email: EPBA@kellencompany.com

 EPBA Transparency Register Number: 71549072613-57