It was the biggest non-secret in the waste and recycling industry when it was announced last month that the UK had missed the 45% target for 2016 battery recycling. Of the 17,232 tonnes collected last year through compliance schemes, 8,745 comprised lead acid batteries. This was 49% of the UK’s overall collection rate, yet physically just 6% of the total tonnage placed on the market.
We have for some time been concerned, and have been very vocal, about the reporting of portable batteries placed onto the market and subsequently recycled.
When the government changed the rules at the start of 2016; tightening the definition of portable batteries to 4kgs and under, it helped industry to classify batteries with greater uniformity. However, the rule change did not address another key issue of how the UK meets the obligation created by smaller producers, for which no party is technically obligated to recycle. In previous years, this has effectively left larger batteries producers to pick up the tab for recycling batteries of smaller producers due to a general over-collection of batteries, around 40 tonnes across the UK last year alone.
Costs
However, increasing costs means schemes and larger producers are only financing their own obligations and appear no longer content to take responsibility for collections by smaller producers. We estimate the bill for recycling batteries on behalf of small producers in 2016 is likely to run into six figures.
There have recently been calls for the Environment Agency and Defra to investigate various issues affecting batteries recycling. The last thing we and our members want to see right now is more change and uncertainty for battery producers.
We don’t want to see an overhaul of the regulations which result in – however well-meaning – further unintended consequences for producers. We don’t believe that yet more guidance will improve the situation. What we would rather see is greater development of the current system, in short, improved clarity on existing chemistry categories.
We want the system to work better for producers who are presently overwhelmed by paperwork when submitting their annual figures. That is why we don’t want to see the baby thrown out with the bathwater and would strongly caution against adding to the present regulations. In our view, the carrot, and not stick approach, is the best way forward.
Data
If the government does decide to implement changes, we would urge these changes to be carefully considered in the context of other producer responsibility regimes and using a longer period of data. After all, it has only been one year since the last change of guidance. A controlled roll-out, especially as the UK prepares to exit the EU, is required.
Producers are already nervously preparing, where they can, for operations beyond Brexit. We want to see them given every chance to succeed in what are certain to be two very difficult years.
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