The Environment Agency has updated its guidance on portable lead acid batteries.
In August 2021 the Environment Agency published guidance “Classifying portable and industrial batteries” with the aim of removing the ambiguity of when a lead acid battery weighing less than 4kg is a portable lead acid battery. At the time the guidance unfortunately failed to clarify the issue, thereby further depressing the demand for portable battery recycling evidence.
Many stakeholders in the battery sector assert that it makes little sense to include any lead batteries within the Waste Battery Regulations, due simply to the fact that they have always been recycled due to the value of the recoverable lead. However, this would require a regulatory change, which is not currently an option. Defra have already indicated that the new battery regulations are a couple of years off, when it is probable that modulated fees will be introduced that would solve the current anomaly.
Last week the EA has published a revision of this guidance. The most significant amendment relates to the definition of “sealed” batteries. The wording of the revised guidance now makes it clear that valve regulated lead acid (VRLA) batteries are considered portable batteries, unless the producer has expert evidence which convinces the EA to the contrary.
In the absence of new portable battery regulations, we welcome the Agency’s renewed efforts to level the playing field for all battery producers. The classification of VRLA batteries, weighing less than 4Kg, as portable batteries needed to be clearly defined and must now be consistently enforced by the Agency.
We look forward to supporting lead acid producers in meeting their compliance requirements.
We strongly believe this will ensure the market works more efficiently and that the increasing reliance of the UK battery producer regime on portable lead-acid batteries to meet the 45% statutory collection targets will be dramatically reduced.
For too long this imbalance has badly affected the whole battery recycling industry, restricting the growth in collection rates, causing serious environmental damage and representing a huge financial cost for many.
Poor collection rates
For more than a decade the imbalance has directly impacted the UK’s underlying battery collection rates. The UK has barely recycled 10% of the total non-lead acid portable batteries reported as placed on the market in 2021. With the likelihood that portable battery recycling targets are going to rise to 65% by 2025 and 70% by 2030 things must change rapidly and substantially.
The unbalanced playing field, caused by the lead acid anomaly, has directly affected the sector’s ability to invest. As an industry, we can now start to recover the time we lost and invest further in the development of the collection and recycling infrastructure needed to meet future targets, ensuring the cost of battery compliance is reduced significantly.
Environmental damage
A 2022 survey from Material Focus has identified that over 600 fires in waste trucks and sites were caused by batteries that hadn’t been removed from electrical appliances.
Research by the Environmental Services Association (ESA) in 2021 found that 48% of all waste fires in the UK were caused by Lithium-ion batteries. How many of these incidents were a result of some of those missing one billion batteries displaced by wrongly declared lead batteries?
These fires have a significant impact on local communities, collection crew and recycling facilities. Fixing the lead acid inconsistency will help reduce the risk of battery fires.
Financial cost
The ESA research also estimated that fires caused by lithium-ion batteries costs £158 million annually to waste operators, fire services and the environment.
We have estimated that un-recycled portable batteries cost the UK £54 million in displaced value from the recycling of precious materials like manganese, zinc, ferrous, cobalt, aluminium, silver and nickel. Closing the lead acid loophole once and for all will increase the recovery of these valuable secondary resources which are vital for the growth of the UK economy.
