A legal basis is essential before a national system for the collection and recycling of spent batteries can be established under the concept of “producer responsibility” in any country. This is because producers will only take on their responsibilities and finance collection and recycling operations if:
1. There is an equal legal requirement on all producers that sell batteries,
2. The Government takes effective enforcement actions against all those who fail to meet their legal obligations i.e. control “free-riders”.
Who are the Producers?:
The definition of producer is important in order to make sure that the law identifies and lays an equal responsibility on all those who sell batteries in a country that will be required to be collected and recycled at the end of their life. For portable batteries, producer will be anyone who:
- Manufacturers or imports and sells batteries under his own brand,
- Sells batteries manufactured by others under his own brand,
- Imports and sells batteries of brands owned by others,
- Sells electrical appliances with replacement batteries,
- Sells electrical appliances with batteries that cannot be replaced by end users,
- Sells batteries by distance selling methods e.g. via the internet.
National systems aimed at collection and recycling of spent batteries requires the co-ordination of a series of separate operations in order for it to function efficiently. It is therefore necessary in the first place to understand and identify the operations involved.
The next step is to define responsibility in such a way that the entire chain of operations are carried out efficiently, at least cost and with minimum burdens on the environment which can be significant if not controlled. For these reasons the EPBA strongly recommends the following division of responsibilities:
Collection Rate Measurement:
EPBA believes that collection rate should be defined in a manner that is measurable with accuracy and set at a level which is achievable in the timeframe.
Over the years a number of methods have been adopted to measure the collection rate including:
a. As a percentage of sales in the same year,
b. As a percentage of sales over a number of years,
c. As a percentage of spent batteries available for collection,
d. As weight collected per inhabitant.
However none of these have proved entirely satisfactory for various reasons. Methods (a) and (b) based on sales data are faulty in there conception because there is no relationship between batteries sold and batteries discarded. Analysis of waste battery collected in The Netherlands carried out by the EPBA have shown that primary batteries can take up to 15 years from the date of purchase to appear in the waste stream.
Furthermore, the weight of batteries sold in any country is very difficult to determine without a national register of producers (see below). Method (c) is technically the correct measure but was rejected by the Council of Member States in 2004 for NiCd batteries due to the costs associated with obtaining statistically significant samples representing the entire municipal wastes stream in a country. Method (d) overcomes the difficulties related to the variability of data which is inherent in the other three methods. It therefore provides a useful and comparable value to measure progress in battery collection over time. However it must be related to the consumption of batteries.
Once the method for the measurement of the collection rate has been defined, the next critical decision relates to setting the level of the target. Here it is important that the level should be achievable within the specified time. The following chart shows the collection rates actually achieved in 7 European countries during 2004.
Factors that should be taken into account before fixing a target are:
- Whether a national battery collection infrastructure has been set up or requires to be set up,
- Number of years of collection operation,
- Level of public awareness.
Targets that are indicative and look for a continuous improvement in the collection quantities are often more effective and offer a greater incentive to their achievement than mandatory targets that are unrealistic.
It is logical and natural, that the collection results depend mainly on the behaviour of the consumers. As batteries do not occupy much space in the household, people tend to keep the batteries in several places in there homes. Consumer studies in Germany, The Netherlands and Belgium show that the large majority of the population know about the collection systems (80-90%), but only a small part of the population (30-50%) uses the systems in place regularly.
The most effective collection schemes are those that are close to the consumer, i.e. where the consumer does not have to take extraordinary steps in order to return used batteries to the collection scheme.
It is difficult for industry to influence the habits of consumers. Public entities are better placed to promote an effective collection system and also to help change consumer attitudes through effective communication.
Register of Producers:
EPBA believes that Governments should establish a national Register of Producers in order to:
- Minimise “free-riders”,
- Support the Government’s intention to prosecute “free-riders”,
- Act as a repository of data which can be used to monitor trends in the battery market and in the effectiveness of the collection and recycling operations.
To realise these objectives the Governments should require producers to:
- Register their business annually; selling batteries without registering should not be permitted,
- Report annually the weight of batteries, by chemical type, they have placed on the market in the preceding 12 months,
- Report how they intend to fulfil their collection and recycling obligation – whether individually or jointly with other producers by joining a collection and recycling organisation,
- Report the weight of batteries collected and recycled in the preceding 12 months.
EPBA believes that collected batteries should be recycled to recover their contained metals rather than disposed of in some other way. However, before recycling the batteries it is necessary to sort them according to their chemical constituents so that they may be treated in processes that can recover their contained metals.
Sorting can be carried out manually, automatically or semi-automatically into the following chemical systems:
- General purpose alkaline manganese and zinc carbon batteries,
- Nickel cadmium and nickel metal hydride rechargeable batteries,
- Lithium ion rechargeable batteries,
- Lead acid rechargeable batteries,
- Button cells
Once sorted the batteries may be recycled by one of more than 40 battery recycling companies in Europe and abroad listed in EPBA’s database.
Alkaline manganese and zinc carbon
Both hydro and pyrometallurgical processes are available to recover zinc, steel and ferro manganese or slag usable in road construction.
Pyrometallurgical processes are used to recover 99.9% purity cadmium that is reused in new NiCd batteries, as well as ferronickel.
Nickel Metal Hydride
Processed to recover nickel, iron and other metals.
Processed to recover cobalt, iron and other metals.
Lead is recovered for reuse in new batteries.
Silver oxide types used in watches are collected by jewelers and recycled to recover silver metal. Other types can be recycled to recover mercury, zinc and steel.
This is defined as the weight of materials recovered from a recycling process expressed as a percentage of the weight of feed material into the process.
EPBA is eager to maximise competition in the battery recycling industry and it is concerned that setting mandatory recycling efficiency targets could reduce competition and favour certain recyclers over others. EPBA is therefore against a mandatory recycling target for batteries. Also, it is not possible to measure a strict recycling efficiency for batteries for the following technical reasons:
- Composition of the feed material entering the process varies considerably and consistently between batches and also between countries due to the market mix of batteries sold and discharge state of batteries collected.
- Many processes integrate battery recycling with other waste feed streams, the determination of recycling efficiency of individual components from batteries versus those from other input streams is therefore very indistinguishable.
- Output of certain recycling processes are further processed at other facilities, the boundaries across which the recycling efficiency is to be measured are blurred.
In consequence the EPBA makes the following recommendations:
- There should be no mandated recycling efficiency,
- Licensing of battery recycling facilities should be according to EUs IPPC requirements,
- If a percentage efficiency is necessary then it should be indicative and not mandatory in order to maximise competition in the recycling sector,
- As an indicative efficiency target 50% is more representative of the available technologies than figures higher than that.
EPBA believes that a system of shared responsibility is essential for any battery collection and recycling system to operate efficiently. This means that all the relevant stakeholders play and pay for their part in the battery return chain. This means:
- End users should return used batteries to collection points,
- Local authorities and retailers should produce collection facilities,
- Producers should pick up the collected batteries and recycle them,
- Producers should not be obstructed from recovering their costs from the end user along the distribution chain,
- Government authorities should enforce the law and prosecute free-riders,
- Battery recyclers should operate in a competitive market.
Experience shows that where these principles are followed costs for the collection and recycling of batteries are the lowest.
The EPBA disagrees with a deposit system, because any such system is not economically feasible and is impractical. There are many difficulties linked to the control of the system through the sales outlets and they add a huge burden to the trade. Furthermore, it does not act as an incentive to collect batteries due to their long lifetime (3-15 years). Finally, the system is very open to fraudulent use.
Sustainable Collection and Recycling Systems:
Based upon its many years of experience with setting up and operating waste battery collection and recycling organizations in several European countries EPBA makes the following recommendation for the setting up of national collection and recycling organizations that are cost effective, efficient and sustainable in the long run:
EPBA is always willing to share its experience and help Governments set up battery collection and recycling schemes.
- Each country should define the most appropriate national collection infrastructure by carrying out pilot studies in 1 or 2 cities lasting at least 1 year,
- Based upon the findings of the pilot studies, collection programmes in large cities should be set up,
- Gradually the collection network should be expanded to cover the whole country over a number of years,
- Wherever possible transportation of collected batteries should be shared with other recyclable wastes such as WEEE, packaging or glass in order to minimize the environmental impacts of transportation and also optimise costs,
- Maximise use of established waste collection infrastructure such as municipalities and retailers for collection of waste batteries from consumers,
- Other opportunities for collecting batteries are at schools, national institutions such as law enforcement, hospitals, airport authorities, etc as well as business and industry,
- Wherever possible collected batteries should be sorted according to chemical type and recycled to recover the contained metals,
- Establish a fair and equitable method for financing the collection and recycling activities.