Key messages:
- The producer definition included in the Batteries Regulation should clearly, coherently, and unequivocally identify the producer in the case of batteries incorporated in vehicles or appliances
- Under the existing Batteries Directive, in the case of batteries incorporated in vehicles or appliances, battery manufacturers are correctly not considered as the producers (in most situations). This is appropriate as battery manufacturers have no information on the geographical market where the battery will be made available to customers, and are therefore unable to comply with the Extended Producer Responsibility (EPR) requirements, particularly the take back obligation
- Using WEEE-like definitions for the producer responsibility is not suitable for automotive, industrial and EV batteries. This would result in allocating EPR to the wrong economic operators
- The current definition assigns producer status differently in the very unique situation where the battery manufacturer and the OEM (Original Equipment Manufacturer) are located in the same Member State. This disparity should be addressed by assigning producer status to the OEM irrespective of the location of the battery manufacturer
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