Brussels, 03 May 2004

EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 15 of the 25 EU Member States and in 2 EU Candidate Countries. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to over 21 million consumers in Europe.

EURO COOP welcomes the European Commission Proposal on Batteries and Accumulators and spent Batteries and Accumulators (COM (2003) 723). It is important to create an EU-wide framework for national battery collection and recycling schemes by setting minimum rules. However, EURO COOP believes it to be crucial that the revised Directive aims at achieving a high level of environmental protection too.

EURO COOP notes that some of its comments made to the European Commission Consultation Document on the Battery Directive Revision have not been included in the Commission Proposal and would hence like to make the following remarks:

• Prevention and Consumer Education

EURO COOP is disappointed to see that no initiatives have been introduced to tackle the true root of the problem, namely preventing excessive use of batteries. EURO COOP believes it is of utmost importance that incentives to promote the use of more environmentally-friendly batteries are included. For instance, schemes to educate and inform consumers, as is currently being done by some EURO COOP member organisations across Europe, to encourage them to adopt more sustainable consumption habits could be one instrument.

• Producer Responsibility and Visible Fee

EURO COOP is pleased to see that producers are to be made responsible for costs related to collection, treatment and recycling of spent batteries and accumulators.

However, EURO COOP notes that even though producers have been made responsible for the costs of historic waste, it will, unfortunately, be possible for them to finance this via the use of a 'visible fee' at the time of sale of new products for a period of four years. In reality this means that consumers end up being responsible for paying the costs of historic waste for producers. At the same time, it leaves retailers with the problem of explaining to their customers why they must pay a fee when buying batteries. EURO COOP is therefore not in favour of the introduction of a visible fee.

• Voluntary Agreements

EURO COOP would once more like to caution against the use of voluntary agreements with producers for collection and recycling of spent batteries and accumulators placed on the Community market as an option to meet the proposed collection and recycling targets. In the past, such systems collapsed as producers did not accept their full responsibilities.

• Batteries and Accumulators containing Cadmium

EURO COOP regrets to see that the use of cadmium in batteries and accumulators placed on the Community market is not going to be banned. EURO COOP would like to reiterate its call for either banning the use of cadmium in batteries and accumulators or, alternatively, to introduce a high fee on batteries and accumulators containing cadmium, due to its hazardous effects on human health and the environment.