The problem
Waste Framework Directive — duty of care
Article 15 of the Waste Framework Directive sets the duty of care for waste. Collection and transport of waste batteries from site to treatment have to sit inside that duty — alongside the Battery Regulation’s own take-back and treatment rules.
Directive 2008/98/EC, Art. 15
Battery EPR does not float free of general waste law. Duty of care is a Union baseline that Member States enforce on the ground.
What to read
- Art. 15 WFD — duty of care
Where LOOBA sits
Core service 1.5 arranges collection and transport through licensed carriers, with the WFD duty of care as an express basis.
Orientation for professional counterparties. Not legal advice.