Position Paper
04 November 2025
EUROBAT feedback on the public consultation on Circular Economy Act
EUROBAT welcomes the European Commission’s initiative to strengthen the circular economy and reinforce the single market for waste and secondary raw materials through the proposed Circular Economy Act.
Batteries are a leading example of circularity in practice. To ensure that the Circular Economy Act is effective and enforceable within the battery sector, EUROBAT recommends the following actions:
- Ensure consistent implementation of the updated List of Waste across all Member States to guarantee harmonised application.
- Align the Circular Economy Act with the EU Batteries Regulation
- Urges the European Commission to further address these obstacles by harmonising requirements for the storage and transport of waste
- The recycling of batteries containing PFAS must be similarly considered
- Introduce a clear and enforceable definition of black mass
- Coordinate and harmonise Extended Producer Responsibility (EPR) schemes across Member States
