Deposit Refund Schemes for Waste Portable Batteries

EPBA supports additional efforts aimed at increasing collection results and getting consumers ‎to bring more used batteries for collection. We believe the key to success is to make it easier for ‎consumers to dispose of their waste batteries.

‎EPBA recognises the success of deposit refund schemes for beverage packaging, but such schemes prove to be inviable for portable batteries for several reasons:

• Beverage packaging are fast moving consumer goods whereas on average the service life of portable batteries can go up to 5 years for alkaline batteries and even much longer for rechargeable batteries. In practice this means that whereas a consumer might have a couple of beverage packaging units to bring to a collection point a week; the ‎number of units of portable batteries one might have to bring to a collection point on an annual basis is not very high (probably not exceeding 10 units). The volume aspect is essential for assessing the attractiveness and feasibility, especially from a cost point of view.

• The price of the product and the level of refund is also an important factor. The relatively low cost of portable batteries per unit makes it difficult to set a level of refund that would be high enough to make it attractive and encourage action while at the same time low enough not to exceed the purchase cost of the product. Important to highlight that given the price level of portable batteries, setting a deposit could also lead to increased fraud and ‎counterfeit issues.

• The risk of deposit tourism is also an important weakness of setting up a deposit refund system for portable batteries, given the different purchasing power levels among member states in Europe. The same level of deposit might be considered too low or too high depending on the member state and if member states were to apply different levels of deposits, consumers might feel encouraged to cross the border looking for more advantageous refunds. One additional bottleneck are the online sales and imports of products where implementing such a deposit system would be impractical.

• Data from different EPR schemes show the most successful collection points are those located in schools, offices and municipalities where no ‎refund is possible and therefore a deposit refund system could not be established. In Belgium for instance, the retail sector accounts for less ‎than 20% of the collected batteries. Focusing collection efforts mainly on the retail ‎sector would be therefore counterproductive. Furthermore, if the retail sector shifts efforts to a deposit refund system, that might impact negatively on the number of available collection points which is an absolute essential aspect over waste portable battery collection.

• Lastly, we feel a deposit refund is a conflicting approach to waste collection and recycling: monetary reward vs. citizen’s responsibility and commitment to the environment.

Instead of a deposit-refund scheme, EPBA encourages authorities to look at other approaches for collection like for instance kerbside collection to be carried out by EPR schemes or by the existing waste collection infrastructure in a frequency that is deemed appropriate.

Another tool to drive consumer awareness and engagement is to include a visible fee which will continuously remind consumers about the costs of battery collection and recycling.

For more information about EPBA’s position on the Commission’s proposed Regulation for Batteries, please visit this page here.