LOOBA Circularity
Professional counterparties

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LOOBA Circularity

The problem

Article 58(7) — financial guarantee

Producers, and appointed PROs, must provide a guarantee covering waste-management costs in the event of non-compliance with EPR obligations, including permanent cessation of operations or insolvency. Member States may add further requirements.

Regulation (EU) 2023/1542, Art. 58(7)

This is the specific obligation most producers still have no concrete answer for — a Union rule whose mechanics are then tightened nationally.

What to read

  • Art. 58(7) financial guarantee
  • Member State competence to add further requirements

Where LOOBA sits

Service 1.3, the Battery EPR Reserve, funds a segregated reserve through a Swiss-based independent Issuer, collateral account, Custodian and Security Agent, plus an independent bank Performance Guarantee, so Art. 58(7) is satisfied directly.

Orientation for professional counterparties. Not legal advice.