eucobat presents priorities for batteries directive review at icbr

Priorities for the Battery Directive Revision

Hamburg – September 24th 2014

1. Eucobat

•  European association of •  Na#onal •  Non profit •  Industry-‐driven •  Collec#on schemes for portable, industrial

and/or automo#ve ba=eries •  Created in 2012 •  17 members •  2013: >40.000 tonnes of portable

batteries collected by members

Main fields of activity: •  Data collec#on and benchmarking •  Collec#on rate/Calcula#on target:

•  Calcula#on methodology •  Defini#ons Portable – Industrial – Automo#ve ba=eries

•  Marke#ng & Communica#on: Consumer awareness •  Safety issues related to collec#on and transport:

•  Research (Fire preven#on – Fire ex#nguishing material) •  Communica#on (guidelines – e-‐learning)

•  Recycling efficiency •  Recycling capacity •  Recycling requirements

1. Eucobat

•  Issues: •  Defini#ons required that are applicable for both POM and collected ba=eries •  As producers usually know the applica#ons of the ba=eries, the dis#nc#on can

be made easily by producers •  At the collec#on point, the usage of the ba=ery cannot be determined •  Interpreta#on of actual defini#ons leads to unrealis#c collec#on rates reported

in some Member States •  A weight limit of 3 kg to dis#nguish portable from industrial ba=eries

corresponds to a reality on the field •  A strict applica#on of a 3 kg weight limit is for some applica#ons (e.g. power

tools) not jus#fied •  The dis#nc#on criteria should ensure that:

•  the producers of the ba=eries collected through the household collec#on channels take the financial responsibility for the opera#onal costs (e.g. small industrial lithium ba=eries)

•  all portable ba=eries can be collected through the household collec#on channels

2. Distinction Portable-Industrial-Automotive


Proposal: •  'Automo#ve ba=ery’: any ba=ery used for automo#ve starter, ligh#ng

or igni#on power. •  'Industrial ba=ery’: any ba=ery:

•  that is not an automo#ve ba=ery, and •  weighing more than 3 kg, and •  designed for exclusively industrial or professional uses, and •  that cannot be used by private households. OR •  used for the propulsion of any type of electric vehicle (excluding e-‐bikes)

•  ‘Portable ba=ery’: any ba=ery that is neither an industrial ba=ery nor an automo#ve ba=ery (including e-‐bike ba=eries)


Practical consequences for collected batteries: •  Household collec#on channels (e.g. retail, municipali#es, schools):

ba=eries considered as “portable” •  Professional collec#on points (e.g. industry, offices, administra#on):

•  Mix of ba=eries that can also be used by private households: ba=eries considered as “portable”

•  Ba=eries >3kg that cannot be used by private households: ba=eries considered as “industrial”

3. Producer Definition / Authorized Representative

•  The producer definition does not comply anymore with the evolution of the battery market.

•  Solution required for the substantial, and growing internet sales to consumers (level playing field)

•  More and more batteries are put on the market integrated in an electrical appliance

Proposal: •  Align producer definition with WEEE Directive •  Introduce the concept of the authorized representative

Specificity of batteries and their chemical composition

Ø  All batteries to be removed from WEEE and end-of life vehicles.

This is the only way to guarantee that all batteries will be recycled according to the recycling efficiency provisions for batteries.

Ø  All batteries and all waste batteries to be regulated by the Battery Directive

Ø  Batteries are not components, sub- assemblies, accessories or consumables of (W)EEE or (end-of life) vehicles.

4. Relationship Other EPR schemes

5. Collection Responsibilities •  Extended Producer Responsibility:

•  environmental policy approach in which a producer’s responsibility for a product is extended to the post-‐consumer stage of a product’s life cycle

•  all actors in the product chain and in society must par#cipate in order to op#mise its effects. Sharing responsibili#es across the product chain is an inherent part of EPR.

•  Consumers have to actively contribute to collection •  Convenient facilities should be set up •  Distributors should provide for the collection, at retail

shops or in their immediate proximity free of charge to end-users and with no obligation to buy a new battery, unless an assessment shows that alternative existing collection schemes are likely to be at least as effective.

6. “Collection Rate/Target” definition

Elements influencing the collection rate: •  Lifespan of the ba=eries and availability for collec#on •  Evolu#on of the ba=ery market •  Interpreta#on of defini#ons •  WEEE collec#on rate •  Removal of ba=eries from WEEE •  General consumer abtude towards waste •  Compe##on

6. “Collection Rate/Target” definition

Eucobat position: •  A collec#on target only adequate if related to the waste

available for collec#on. •  Concept already integrated in the new WEEE Direc#ve •  Methodology allows taking into account:

•  differing life cycles of the ba=eries and of the appliances they are used in

•  market situa#on and satura#on. •  It requires obliga#on for all actors to report to the na#onal

authori#es and the obliga#on for the member states to monitor all waste streams.

•  WEEE Directive: •  Proper treatment of waste electrical and electronic equipment (WEEE)

includes the removal of ba=eries from any separately collected WEEE (Ar#cle 8.2 and Annex VII)

•  ‘Removal’ means manual, mechanical, chemical or metallurgic handling with the result that hazardous substances, mixtures and components are contained in an iden#fiable stream or are an iden#fiable part of a stream within the treatment process. A substance, mixture or component is iden#fiable if it can be monitored to verify environmentally safe treatment. (Ar#cle 3.1.l)

7. Batteries in WEEE

•  European Standard EN 50625-1: •  Ba=eries accessible without using tools: to be removed before any

treatment process that can cause damage to them •  Ba=eries not accessible without using tools: to be (part of) an

iden#fiable stream •  Special precau#ons and safety measures for WEEE, which may

contain lithium ba=eries


•  Battery Directive (Article 11): •  Appliances should be designed in such a way that waste ba=eries and

accumulators can be readily removed. •  Where they cannot be readily removed by the end-‐user, waste

ba=eries and accumulators should be readily removable by qualified professionals that are independent of the manufacturer, such as independent repair and service centers and WEEE dismantlers.

•  Appliances in which ba=eries and accumulators are incorporated should be accompanied by instruc#ons on how those ba=eries and accumulators can be safely removed by either the end-‐user or by independent qualified professionals. Where appropriate, the instruc#ons should also inform the end-‐user of the types of ba=ery or accumulator incorporated into the appliance.


7. Batteries in WEEE Proposal:

In order to ensure that all ba=eries are removed from electrical and electronic appliances, and to prevent safety risks, Eucobat proposes that the provisions of the WEEE Direc#ve and/or the European standard EN 50625-‐1 should be amended in such a way that:

•  All ba=eries have to be removed from any separately collected WEEE prior to treatment of WEEE or during the treatment process provided that this process can ensure that ba=eries can be separated in a dis#nct stream and that the ba=eries remain undamaged,

•  The only excep#on could be the ba=eries that are intended to ensure a con#nuity of power supply for safety, performance, medical or data integrity reasons,

•  The integrity of the ba=eries should be maintained during the removal process, and •  Quan#fied objec#ves should be imposed on the WEEE dismantlers for the removal of

ba=eries from the WEEE categories 5 (small equipment) and 6 (small IT and telecommunica#on equipment), as defined in annexes III and IV of the WEEE Direc#ve.

8. Recycling Targets and Requirements

•  Increasing importance of mobile appliances ⇒  Con#nuous growth of ba=eries in general and lithium ba=eries in par#cular ⇒  Constraint to recycling capacity

•  Batteries composed of an increasing number of heterogeneous, low value materials in different variations

•  Decrease of valuable materials used in manufacturing process

=> Rethinking required of recycling process

8. Recycling Targets and Requirements

Urgent need for processes that balance energy consumption and cost on the one hand with an ecologically worthwhile raw material recovery on the other hand ⇒ Eucobat pursues a future-oriented recycling strategy utilizing:

•  Pyrometallurgical recycling and/or •  A combina#on of mechanical and thermal recycling, especially with regard to the

recycling of heterogeneous ba=ery mixes containing e.g. lithium or AlMn/ZnC ba=eries.

9. Information requirements

•  Information to end-users: •  Labelling system should provide end-‐users with transparent,

reliable and clear informa#on on any heavy metals they contain •  However, given the small size of the ba=eries and in order to avoid

an informa#on overload, the informa#on to the consumers and other end-‐users should be limited to the issues where he can have a real environmental impact.


•  Information to national producers: •  Most na#onal importers of appliances with integrated ba=eries, which

are considered as ba=ery producers, don’t dispose of the required technical informa#on to report to the Member State or a collec#on scheme

•  It is required that the instruc#ons accompanying the appliances on how to safely remove the ba=eries and accumulators , also contains informa#on on the types of ba=ery or accumulator incorporated into the appliance (at least the chemical composi#on and the weight).

•  By using an exis#ng document, addi#onal administra#ve burden for the manufacturers of the appliances is prevented.


•  Information to waste operators: •  In order to ensure an appropriate recycling of all collected ba=eries, an

effec#ve sor#ng of these ba=eries prior to the recycling process is required.

•  However, such sor#ng is today not feasible for a large amount of (mostly industrial) ba=ery packs and/or individual cells from such ba=ery packs, as the chemical composi#on of these ba=ery packs and/or individual cells is not indicated.

•  Therefore, it is required that all ba=ery packs and individual cells for ba=ery packs are labelled with at least the chemical family.

•  This labelling should be the subject of standardiza#on.

10. Summary

1.  Undisputable definitions of P-I-A (applicable for POM and collected) 2.  Producer definition and authorized representative aligned with WEEE

directive 3.  All (waste) batteries regulated by Battery Directive 4.  Collection is a shared responsibility 5.  Collection target in function of batteries available for collection 6.  All batteries to be removed from WEEE 7.  Recycling requirements that balance energy consumption with an

ecologically worthwhile raw material recovery 8.  Information requirements with added value for all stakeholders

Thank you for your attention

eucobat presents priorities for batteries directive review at icbr

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