EUROBAT feedback on the update of the draft Commission delegated decision amending Decision 2000/532/EC as regards an update of the list of waste in relation to battery-related waste

In this position paper, EUROBAT expresses support for the draft delegated act supplementing the List of Waste with new codes for waste batteries of new chemistries. It supports the classification of intermediate fractions of waste batteries, including “black mass”, as hazardous – a development that will boost availability of second materials for lithium-ion batteries in the EU single market.

However, EUROBAT ‎fears that the complexity of the new list specifically the high number of codes (54) would make it inapplicable on ‎the ground. ‎ While we support ending the fragmentation of battery-related waste codes across national or even regional ‎lines, and adapting the list to technical progress, we think the harmonization will only reduce administrative burden if it provides stakeholders with an easy-to-use ‎approach.