And, the organisation – which represents council recycling officers – warned that, if councils were not involved, it could make it harder for the UK to reach its battery collection targets.
The consultation was held as the government looks to introduce the second part of the system that the UK will use to meet the EU Batteries Directive target of collecting 25% of waste portable batteries by 2012.
Money
LARAC said that it was particularly concerned at there being no responsibility in the plans for battery compliance schemes to provide councils with the money to run collection schemes.
“Given that the targets in the Directive are extremely challenging it is critical that local authorities are encouraged to introduce alternative collection schemes to maximise capture levels of this material from the household waste stream,” it said.
Concerns have already been raised that, due to the low levels of waste portable battery recycling currently taking place in the UK, and the delay in introducing the full UK system, the EU targets could prove hard to achieve (see letsrecycle.com story).
LARAC explained that the relatively low tonnages of batteries that would be required from councils by battery compliance schemes (BCS) meant that, without funding, there was little incentive for councils to run schemes, and in particular “high yielding and potentially high cost” options such as kerbside.
As a result, it said: “LARAC would welcome some form of financial pool for local authorities wishing to introduce collection systems.”
Urban
It also warned that compliance schemes could choose only to work with large councils in urban areas which would offer a lower cost route to collecting the batteries they needed to meet their members' obligations than rural areas.
It explained: “LARAC is concerned that proposed regulations may allow for BCS to cherry pick the local authorities that they wish to work with. This is likely to result in some authorities, particularly in rural areas, being overlooked by BCS in favour of larger authorities.”
Given that the targets in the Directive are extremely challenging it is critical that local authorities are encouraged to introduce alternative collection schemes
LARAC consultation response
“LARAC would like to see some requirement for BCS to ensure that all local authority areas collecting batteries would be allocated a compliance scheme,” it added.
And, the organisation also criticised the lack of plans for a national awareness campaign in the government's proposals, claiming that “with BCS having only an option to assist local authorities with communication materials it is likely that collection schemes will not be utilised to their full potential.”
BRC
The government's plans for battery recycling have also come under attack in the British Retail Consortium's (BRC) response to consultation. The consultation was originally launched in December 2008.
In its response, which was published earlier this week, the BRC was particularly critical of the government's proposal to bring the regulations, and associated collection systems, into force on January 1 2010, and instead called for an April 6 2010 start date.
The BRC's director general, Stephen Robertson, explained: “This is the right aim but the wrong timing. Retailers are happy to provide an in-store collection system but having it ready to go right in the middle of the vital Christmas and New Year sales period will be a nightmare.
“The Government's failure to meet last September's required implementation date is no reason for setting retailers this unworkable deadline or leaving holes in their plans.
“To minimise cost and vehicle journeys, retailers must be allowed to combine collection from stores with deliveries. Online retailers need to be clear how they meet their obligations and in-store collection must be just part of a consistent collection system that encompasses other types of waste. An April start-date would allow all involved to get this right,” he added.
The BRC also strongly advocated the introduction of an integrated end-of-life infrastructure, including WEEE, batteries, plastic and glass, which “would put the consumer at the heart of the waste collection process”.
In particular it claimed an “easy to understand recycling scheme for all waste streams would reduce consumer confusion and improve overall collection rates.”
And, it called for a single approval system to be introduced for compliance schemes covering batteries, WEEE and packaging waste, arguing that “requirements for schemes to be approved separately increases approval costs and adversely affects efficiency.”
Wastecare
Further criticism of the government's plans came from Wastecare, the Leeds-based compliance scheme which launched a pre-compliance scheme for batteries manufacturers known as BatteryBack in May 2008 (see letsrecycle.com story).
Speaking last week, the company's managing director Peter Hunt echoed concerns raised by both the BRC and LARAC about the financial impact of the government's proposals.
“What we see in the latest proposal is a costly and administratively burdensome set of rules that will result in increasing the cost of batteries for everyone, whilst possibly forcing some battery producers out of the market,” he said
Mr Hunt claimed that, instead of introducing battery regulations, the government should have “simply” added a new category of 'separately collected batteries' to the existing WEEE categories.
As well as calling for small producer exemption to be lower than the three tonnes placed on the market per year that has been proposed, he also called for the exemption which means that small retailers selling less than 16kg of batteries a year do not have to provide collection facilities should be increased.
And, Mr Hunt also called for the interim collection targets proposed for 2010 and 2011 to be made mandatory, and for evidence trading to be allowed “from the outset”.
He said: “We do not see the problem in meeting the European targets for recovery, we do see a problem with this heavy-handed approach to compliance and the unnecessary cost to both industry and the public.”
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