The 2009 Regulations apply to all types of batteries and accumulators regardless of their shape, volume, weight, material composition or use, and whether or not they are incorporated into appliances.  Requirements differ, however, depending on whether batteries or battery packs are classed as portable, industrial or automotive. This is significant given the historically low rate of recycling of portable batteries, at least in relation to those that are used at home; it has been estimated that just 4% of the 600 million household batteries sold each year are recycled.

New obligations

Manufacturers and retailers of domestic appliances and other items of electrical and electronic equipment distributed and sold with portable batteries should know their obligations in relation to battery recycling. In a nutshell, they are:

• If you place one tonne or more of portable batteries on the market per year (which may include selling products with batteries included) you will have to pay for the collection, recycling and disposal of waste batteries in proportion to your market share from 1 January 2010.  You will have to register with a Battery Compliance Scheme that will arrange the collection, recycling and disposal of batteries on your behalf.
• If you place less than one tonne of portable batteries on the market per year (again which may include selling products with batteries included) you will not have to pay for the collection, treatment and recycling of batteries.  However, you will have to register with the appropriate regulator, such as the Environment Agency in England and Wales, SEPA in Scotland and NIEA in Northern Ireland.
• If you sell 32kg or more of household batteries you will have to take back these batteries in-store, free of charge, when they become waste.

Arrangements for collections

Fulfilling collection obligations requires a supporting infrastructure and, fortunately the Environment Agency has recognised the importance of the postal system in this respect by relaxing rules that might otherwise have inhibited posting waste batteries to recyclers.  Specifically, the Environment Agency has overseen an easing of Hazardous Waste and Duty of Care requirements to the extent that:

• Non-hazardous batteries need not be accompanied by a waste transfer note when posted.
• For hazardous batteries, the Post Office or courier does not need to complete the part of the consignment note that might have applied to them as waste handlers.  However, a consignment note must still accompany hazardous waste batteries and be party to business-to-business exchanges.
• When the Royal Mail or courier is carrying hazardous batteries, they will not need to register their premises as hazardous waste producers.

This is helpful, but the real test will be in how well Battery Compliance Schemes operate and how the larger retailers arrange in-store collections.  The deadline for applying to the Environment Agency for approval to run a Battery Compliance Scheme has now passed and we are currently waiting for the Environment Agency to publish a list of candidate schemes followed by a list of approved schemes. These lists are due to be announced in summer and autumn this year.  Producers wait with interest to compare fees and services.

Equally important are local battery collection initiatives. For example, AMDEA staff have been struck by the emergence of black and pink battery recycling boxes near our office in the London Borough of Camden. This is part of an initiative by Camden Council to increase battery recycling, which sits alongside its ‘Simply Drop' project that is seeking to encourage the recycling of batteries together with old mobile phones, digital cameras and MP3 players in the Borough through cash incentives and a free post-back service.  Such initiatives are, however, few and far between and what works in one area of the country may not work in another. 

Ultimately, Battery Compliance Schemes are likely to drive higher collection rates and, since they will also have responsibility for treating and recycling the waste batteries they collect, they will help to achieve higher rates of recycling.  We shall find out how they fare in the years ahead.

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