The discussion during the second session “Batteries under the law — obligations of manufacturers and recyclers” focused on the changes introduced by the Battery Regulation and how the market should prepare for them — from registration with BDO, through new categories of batteries, to the expansion of the collection network and the role of the Transport Technical Supervision (TDT).

The following took part in the debate:

Moderator:
▪️ Filip Gabryelewicz — Development Director, Wastes Service Group

Panelists:
▪️ Justyna Zyga — Legal Counsel, ECO LEGAL Law Firm
▪️ Albert Kania — COO, F5A New Mobility Research & Consulting; Senior Manager, PSNM
▪️ Katarzyna Błachowicz — Vice-President of the Management Board, Coordinator of the Circular Economy and Recycling Cluster
▪️ Michał Kusz — President of the Management Board, Green Recovery Organization
▪️ Piotr Jarmowicz — Chief Expert, Department of Industrial Regulation, Ministry of Development and Technology

The main threads of the panel:

♻️ Regulation and Supervision — The new Battery Act will replace the 2009 regulations, strengthening supervision in the consumer segment and introducing TDT for industrial batteries, SLI and EVs.

🗂️ BDO and manufacturers' obligations — registration with BDO is the starting point; it will be necessary to add LMT and SLI categories and implement reporting and financing of the system.

🎯 Collection goals and costs — The target for portable batteries increases to 63%, which requires expanding the collection network and increasing budgets; some organizations may struggle with the new requirements.

🏗️ Infrastructure and education — separation of streams of light consumer batteries from heavy batteries (EVs, energy storage), mobile collection points, seasonal activities and intensive user education.

🧩 Ecodesign and Collaboration — Designing products and processes in accordance with GOZ and early value chain collaboration to prevent system disruptions.

🔋 EV and the recycling horizon — extending the life cycle through the “second life” of batteries; a real recycling boom expected around 2040

The panel concluded: “Without BDO registration, there is no activity in the battery market — and we are facing higher collection targets and new TDT supervision.”

Thank you to all the panelists for their valuable comments. We hope that the discussion will contribute to the smooth implementation of new regulations and the development of a competitive market in the spirit of the circular economy.

Honorary Patronage:
Ministry of Climate and Environment, Marshal of the Lower Silesian Voivodeship — Paweł Gancarz, AGH University of Krakow, Institute of Mineral Resources and Energy Management of the Polish Academy of Sciences

Patronage:
Business Centre Club, PSNM

Partners:
Green Recovery Recovery Organization, ECO LEGAL Law Firm, Mercedes-Benz Duda-Cars, Brzezno Palace, Greencell