SolarPower Europe and its Battery Storage Europe Platform welcome the opportunity to provide feedback on the public consultation on green-listing certain waste streams for the purpose of recovery among Member States. As the voice of the solar PV and battery energy storage system (BESS) sectors in Europe, we stress the importance of establishing a robust, coherent, and forward-looking legislative framework that lays the foundation for an efficient single European market for waste. The purpose of which should ensure the necessary framework conditions, to allow for the appropriate recycling and recovery of critical and strategic raw materials of components such as solar PV panels and battery modules, while supporting the EU’s decarbonisation and energy security objectives.
Please see our full response in the following position paper, and the summary points below.
Promoting a single European market for waste to improve recycling
SolarPower Europe and its Battery Storage Europe Platform's consultation response on green-listing certain waste streams for the purpose of recovery among Member States.
Read the paper
Single market
A single European market for waste is essential to scale recycling for solar PV panels and batteries. Streamlining cross-border shipments and greenlisting these materials under Basel code Y49 would reduce costs and enable efficient recovery of critical raw materials.
Standards
Harmonising recycling standards, such as making European Committee for Electrotechnical Standardisation (CENELEC) standards mandatory, ensures high-quality, consistent treatment of solar PV and battery waste across Member States. This prevents suboptimal practices and supports circular economy goals.
Recovery
Aligning green-listing with the Critical Raw Materials Act and simplifying procedures will boost recovery of strategic materials, reduce supply risks, and foster industrial opportunities. Trans-regional recycling hubs and streamlined producer responsibility processes are key to economic viability and EU competitiveness.
Batteries
Battery modules, though often classified as hazardous, have high critical raw material recovery potential. Greenlisting with proper safeguards and technical thresholds can enable safe, circular management, and support the growth of EU battery recycling.
Competitiveness
Lowering administrative burdens and increasing competition among recyclers can reduce recycling prices and absorb transportation costs. This supports the EU’s long-term strategy for resource recovery and industrial competitiveness.
Supply chain
Improved waste flow and critical raw material recovery will reduce geopolitical supply risks and create industrial opportunities and jobs within the EU. Developing EU value chains for CRM recovery is a strategic priority.
Strategic Partners of the Battery Storage Europe Platform
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