The study was carried out by consultants Ecotec. It was commissioned in response to concern in the secondary lead industry that the revised special waste regulations, which came into force last September (ENDS Report 255, p 35 ), would discourage collection and recycling of lead-acid batteries. The regulations, which implement EC waste rules, introduced a requirement to prepare consignment notes for battery shipments and imposed a charge of £10 for consignments of five batteries or more.
About six million lead-acid batteries are discarded in the UK each year. The recycling rate fluctuates with changes in lead prices, but is generally around 90%.
Ecotec assessed the impact of the regulations in South Yorkshire by interviewing 35 businesses in the battery recovery and recycling chain. Only a summary of its findings has been released by the DTI on the grounds that the full report contains information gathered in confidence.
Ecotec found that 1,380 tonnes of batteries per year are supplied to Enthoven's and Britannia's lead smelters from South Yorkshire. About 87% come from scrap yards, with the remainder originating from civic amenity sites, battery producers, distributors and large-scale collectors such as G&P.
"Itinerant" and other small collectors play an important role, collecting 22-37% of the batteries from small garages and retail outlets and delivering them to scrap yards.
The consultants found that the Environment Agency has not been enforcing the new regulations rigorously. Their summary says that inspectors "do not appear to be getting to the smaller players in the collection system," and "appear to be turning a 'blind eye' to illegal practices at certain scrap yards and garages." And while a "significant" number of scrap yards have been turning away illegal deliveries, "some smaller yards, in particular" are still accepting them.
Overall, Ecotec found no convincing evidence that battery supplies to the smelters have been reduced. But the position is finely balanced. Some scrap yards have stopped accepting batteries because the low price of lead has been compounded by the "hassle" of completing consignment notes. Some of this trade has been diverted to other yards which rely on itinerants to supply other, more valuable materials. Ecotec believes that a crackdown on illegal activity by the Agency could push the current collection rate of over 90% to 80% or less.
The key problem, Ecotec believes, is that reliance on itinerant and small collectors makes the recovery system difficult to regulate. One option would be to make it easier for them to comply with the law by raising the threshold for consignment notes to 30 batteries.
The alternative would be to eliminate small illegal operators from the system - an option "perhaps more in keeping with the aims of the regulations." Suggested ways of doing this are:
The first two mechanisms would have significant storage and transportation implications for retailers. Follow-up changes to the regulations - such as raising the threshold for consignment notes and/or waiving the fee for small quantities of batteries - might be needed to ensure that garages and retailers had an incentive to deliver used batteries to a central collection point. The DTI intends to discuss Ecotec's findings and proposals with the Agency and Department of the Environment.