Government has set out its plans to increase battery recycling and treatment in a consultation paper on implementing of the EU’s battery Directive. The key challenge will lie in meeting the Directive’s targets for collecting batteries from households.
Responsibility for implementation has been split between two departments. The Business Department (BERR) is leading on policy for industrial and automotive batteries; the Environment Department (DEFRA) leads on household batteries.
Producer responsibility: Battery producers will be required to pay for collecting, treating and recycling batteries and retailers will be forced to take back waste batteries from consumers. Appliance manufacturers will be required to ensure batteries can be readily removed for easy collection, treatment and recycling.
Producers are defined as the businesses that place a battery on the market for the first time, including internet retailers. Small producers may be exempt, but no threshold to define them has yet been put forward.
Compliance schemes for household batteries: Several models are suggested. There could be a single national compliance scheme or multiple schemes, with or without a coordinating body.
Departments say a proliferation of schemes is confusing to producers and risks not meeting targets. This approach is also burdensome to regulators. However, an overseeing body could run public information campaigns and ensure collection is coherent.
A single scheme would help coordinate collections, provide more clarity to producers and deliver a coherent public information campaign. But costs may be higher and competition would need to be built into the system.
Collection of household batteries: To meet the target 25% collection rate by 2012, the UK must collect up to 7,500 tonnes of batteries. Only around 900 of the 30,000 tonnes of household batteries placed on the market each year are collected. The target rises to 45% in 2016.
Initial results from Waste and Resources Action Programme collection trials show that if every council collected batteries by kerbside collection, 2,000 tonnes would be captured. The rest would have to be gathered from retailer take-back, community drop-off points and the commercial sector. ERM estimate 33,000 to 65,000 institutional drop-off points may be needed by 2016.
Interim targets: DEFRA thinks these are "beneficial" in remedying flaws before target years, but falls short on suggesting what they might be. Instead, it says it will work with industry to develop them. Previously suggested figures were criticised for not being based on robust data (ENDS Report 391, p 51 ).
Treatment: Facilities are to meet "recycling efficiencies" by 26 September 2011. These targets set the percentage by weight of batteries that are to be recovered. For lead-acid batteries the target is 65% recovery, for nickel-cadmium 75% and for all other batteries the target is 50%.
Evidence for compliance: Documentary evidence showing that batteries have been received at treatment and recycling facilities and that the relevant efficiencies have been met will be the basis for ensuring compliance. Producers may trade evidence, but it will not be formalised as with the packaging waste regime.
Detailed rules on calculating recycling efficiencies are not expected from Europe until March 2010. The matter is complicated as batteries may be passed between several facilities during recycling. The Departments suggest facilities could provide a mass balance of the amount of materials entering or leaving. Alternatively, regular sampling by regulators could assess whether facilities achieve the efficiencies they claim. If batteries are exported for treatment, exporters will be required to provide documentation.
Industrial and automotive batteries: BERR appears satisfied that existing market forces could deliver the Directive’s targets for industrial and automotive batteries. Nearly all are already collected and recycled because of the high value of materials they contain, particularly lead. Current treatment and recycling levels are broadly equivalent to those required by the Directive.
The first option is a business-as-usual approach; however, a safety net will be put in place that could bring in producer responsibility requirements if the value of materials nose-dived. An alternative option for full producer responsibility has also been put forward. Here producers would have to join a producer responsibility scheme, be required to take back spent batteries and report on their treatment and recycling.
Disposal: Automotive, industrial and portable batteries may not be disposed of at landfill sites or be incinerated. Treated residues of portable batteries that contain cadmium, mercury or lead may be disposed of by landfill or underground storage, such as the Minosus facility in Cheshire (ENDS Report 380, pp 13-14 ). But this would be only when there is no viable end market available, or as part of a strategy to phase out heavy metals on the basis of a detailed assessment.
New batteries: New household batteries with high levels of cadmium face a ban and there will be continued mercury restrictions. Labelling of capacity, chemical symbol and "wheelie bin" collection symbols will be required. Detailed rules on labelling requirements, including harmonised methods for the determining battery capacity, is expected from the commission by 26 March 2009. Test purchases, powers to require production of documents and information, entry and inspection will be used to enforce heavy metal restrictions.
A second, shorter consultation on the draft regulations will take place later this year. Member states are required to transpose the Directive into national law by 26 September 2008. Devolved administrations may decide to issue their own legislation. The deadline for responses is 13 March 2008.