The Battery EPR Reserve, then optional site restoration.
LOOBA’s services are organised in two tiers, both aimed at developers and asset owners. Tier 1 is the mandatory-aligned core every registered producer or asset owner needs. Tier 2 is an optional extension for ground-lease structures and lenders requiring independent site-level security.
Tier 1 — Core
Battery EPR Reserve
Discharges the producer’s Regulation (EU) 2023/1542 obligations end-to-end.
Every producer / asset owner of an industrial battery or BESS >2 kWh
1.1
Core
EPR Registration & Compliance Administration
LOOBA registers the battery under the correct category in every Member State where it is placed on the market (Art. 55), and administers the producer’s ongoing reporting duties (Art. 74–76) — removing the need for an in-house compliance function per jurisdiction.
For: Producers and any asset owner/integrator caught by the Article 44 “inherited manufacturer” rule
Registration in every Member State of placing on the market (Art. 55)
Correct battery-category filing
Ongoing reporting administration (Art. 74–76)
Coverage where Article 44 inherited-manufacturer duties attach
No in-house compliance function required per jurisdiction
1.2
Core
Recycler-Agnostic Network Management
LOOBA competitively selects, contracts, monitors and — if necessary — replaces the approved recycler performing the physical treatment, so the client never carries single-recycler counterparty risk.
For: All Tier 1 clients
Basis: Art. 70/71 treatment obligations; LOOBA’s own approved-recycler framework
Competitive selection of the approved recycler
Contracting and monitoring of physical treatment
Replacement of the recycler if necessary
No single-recycler counterparty risk on the client
1.3
Core
Battery EPR Reserve — the Article 58(7) Financial Guarantee
A single, volume-tiered fee at registration funds a segregated reserve, structured through a Swiss-based independent Issuer, a product-specific collateral account, a Custodian and a Security Agent, backed by an additional independent bank Performance Guarantee. This satisfies the Article 58(7) financial guarantee requirement directly — the specific obligation most producers today have no concrete answer for.
For: All Tier 1 clients
Basis: Regulation (EU) 2023/1542, Art. 58(7)
Single volume-tiered fee at registration
Segregated reserve via a Swiss-based independent Issuer
The same reserve responds to a Replacement Event (mid-life, degradation-driven replacement) and the eventual Decommissioning Event (end-of-life), however many replacement events occur first. This closes the two cost blocks — mid-life replacement and end-of-life decommissioning — that are typically absent from a project’s financial model.
For: All Tier 1 clients, particularly BESS asset owners
Basis: Art. 59 take-back duty (no cap, no expiry, for industrial/EV/SLI batteries)
Closes mid-life replacement and end-of-life cost blocks
1.5
Core
Collection & Transport Coordination
LOOBA arranges collection and transport of waste batteries from the client’s site to the approved recycler, through licensed carriers, compliant with ADR dangerous-goods rules and, where cross-border, the Waste Shipment Regulation.
Collection from the client’s site to the approved recycler
Licensed carriers
ADR dangerous-goods compliance
Waste Shipment Regulation where the movement is cross-border
1.6
Core
Treatment & Recycling to Regulatory Targets
Delivery of the Annex XII recycling efficiency and material recovery targets (e.g. 65%→70% lithium recycling efficiency; 50%→80% lithium material recovery) through the approved recycler network, with verification under Delegated Regulation (EU) 2025/606.
For: All Tier 1 clients
Basis: Art. 70, 71, Annex XII
Annex XII recycling-efficiency targets
Annex XII material-recovery targets (including lithium trajectories)
Treatment through the approved recycler network
Verification under Delegated Regulation (EU) 2025/606
1.7
Core
Second-Life / Repurposing Facilitation
Where a degraded battery is a viable candidate for a second-life application rather than immediate recycling, LOOBA facilitates assessment and placement ahead of eventual recycling.
For: BESS asset owners with degrading, not-yet-end-of-life packs
Basis: Art. 73
Assessment of second-life viability
Placement ahead of eventual recycling
Eventual recycling remains in the same reserve path
1.8
Core
Insolvency & Step-in Protection
Two independent protections operate together: if an approved recycler fails, LOOBA appoints a replacement from its network with no interruption to the client’s compliance; if the Issuer of the reserve itself fails, the Security Agent takes exclusive control of the collateral account, protecting it from the Issuer’s other creditors.
For: All Tier 1 clients
Basis: LOOBA reserve architecture; addresses both recycler-level and Issuer-level failure
Recycler failure: replacement from the network, no compliance interruption
Issuer failure: Security Agent exclusive control of the collateral account
Reserve protected from the Issuer’s other creditors
Reporting and passport data close-out confirming the battery’s end-of-life treatment, for the client’s own audit trail and market-surveillance readiness.
For: All Tier 1 clients with >2 kWh industrial batteries
Basis: Art. 77
End-of-life treatment reporting
Passport data close-out
Client audit trail
Market-surveillance readiness
Tier 2 — Optional
Site Restoration Assurance
Covers what sits outside the Battery Regulation entirely.
A separately scoped, separately priced reserve covering the civil/BOP decommissioning cost block that sits entirely outside the Battery Regulation: foundations, enclosures where applicable, power conversion equipment, cabling, and land restoration. The exact boundary is fixed per project as a technical schedule to the Participation Agreement.
Basis: Outside Regulation (EU) 2023/1542 — general civil, environmental and lease/contract law
Separately scoped and separately priced from the Battery EPR Reserve
Foundations and enclosures where applicable
Power conversion equipment and cabling
Land restoration
Project-specific technical schedule to the Participation Agreement
2.2
Optional
Landowner / Lessor Co-Beneficiary Designation
The landowner can be named a co-beneficiary, or beneficiary of last resort, under the Site Restoration reserve — giving direct, independent recourse that does not depend on the continued solvency or existence of the SPV or its current shareholders.
For: Landowners/lessors in ground-lease structures
Basis: Contractual beneficiary designation under the Site Restoration rider
Co-beneficiary or beneficiary-of-last-resort designation
Direct independent recourse for the landowner/lessor
Recourse not dependent on SPV solvency or current shareholders
2.3
Optional
SPV Change-of-Control Protection
Recommended contractual mechanics for the Participation Agreement and Site Restoration rider: automatic continuity of registration and reserve rights through any change of control, notice-of-change-of-control covenants, and landowner consent rights over any release or substitution of their beneficiary status.
For: SPV-structured projects, particularly those likely to be sold via share deal
Basis: Addresses the covenant-erosion risk identified for SPV/share-deal structures
Automatic continuity of registration and reserve rights through change of control
Notice-of-change-of-control covenants
Landowner consent rights over release or substitution of beneficiary status
Services as currently structured. Swiss issuance and collateral architecture remain subject to final legal documentation.
Register with your company name and email, indicate who you are, and tell us what you want. Producers are asked for battery types as part of the information request.
