Last reviewed 30 March 2015

The EU Battery Directive sets out requirements regarding the treatment and disposal of waste batteries and accumulators. This presents organisations with some challenges. Alan Field explains some of the key points to consider.

The Batteries and Accumulators and Waste Batteries and Accumulators Directive 2006/66/EC (the EU Battery Directive) has led to battery manufacturers facing progressively greater requirements concerning the treatment and disposal of waste batteries and accumulators (ie rechargeable batteries). Further regulatory requirements arising from the directive are in the pipeline. For those in charge of facilities and waste, especially at complex sites with multiple tenants, it can be a challenge to ensure that both compliance and recycling initiatives are met.

Batteries, especially rechargeable ones (often known as accumulators), are still used in many building systems devices — sometimes for back-up purposes — and tenants will also generate these from their own office or merchant services equipment, among other devices. In other words, it is not only battery manufacturers and distributors who need to be aware of the directive’s requirements.

Before looking at batteries (this term will also include accumulators for our discussion), it is worth considering the practical issues that should always be clarified for any non-general waste streams.

While, at first glance, contracts should always be clear about duty of care for waste streams, it is worth verifying that all parties — at operational level — do understand these in a consistent way. There is sometimes too much reliance on what the contract says, yet wider questions about how the contract aligns with leases and service charge agreements for tenants are not considered. While it is the landlord’s responsibility to ensure the contract is consistent with these other agreements in terms of duty of care, it is the facilities manager’s headache on the ground! Therefore, clarifications should be sought, especially where the facilities manager (FM) is not the managing agent of the site.

For example, some service agreements may say that the landlord is responsible for general waste streams only but the tenant may — in ignorance or otherwise — put things, such as batteries, into the general waste. The landlord, especially at some high-end sites, may expect the FM to assist in educating tenants about recycling expectations — but this needs to be agreed in advance.

Even when, more typically, the landlord directs the tenant to the fact that they have their own sole duty of care responsibilities, the landlord’s agent may still control any access to the site for waste contractors, ie this is typically controlled by the building manager who may be the FM contractor’s employee. Again, liaison is necessary and clear lines of demarcation must be agreed where disputes arise about waste streams, storage or the actions of waste collectors.

On larger sites, the FM contractor is usually responsible for the disposal of waste from the common parts, including waste generated by themselves or their contractors. There needs to be a clear understanding concerning leased equipment or equipment where the service contract requires the contractor to remove all parts and other maintenance waste from site.

Usually, with the first example, the battery belongs to the company leasing the item and there is no argument that they should be able to take away their property, ie it is not waste. With the second example, where the battery technically belongs to the FM contractor or the landlord, then the legalities of simply removing waste from site by, say, a service technician without appropriate duty of care documentation needs to be carefully considered in advance. The same issue applies to any tenant who may have similar agreements with their suppliers/contractors.


Where waste streams are managed from the site by one waste contractor — especially if it is one of the nationwide contractors — they will often arrange battery collection for you, sometimes through a sub-contractor. Of course, as part of your own duty of care checks you will be finding out what they will be doing with these batteries.

One current issue is that there is only limited re-processing capacity in the UK for certain types of batteries (eg alkaline manganese batteries may need to be chemically treated to separate the individual constituent materials — the process is often known as hydrometallurgical treatment). This could lead to your site’s waste batteries being exported abroad, maybe even to the Far East. Battery miles — rather like food miles — might impact on the organisation’s own carbon reduction targets. In other words, always ask the waste contractor for the details so an informed decision is possible.

Batteries, typically, fall under two categories: non-hazardous (such as alkaline batteries) and hazardous (such as lithium and lead acid batteries). If there is any doubt about the composition of the battery or the EWC (European Waste Catalogue) code that applies, then the manufacturer or supplier should be always be consulted.

As with all hazardous waste, the appropriate consignment note must be issued and, of course, cannot be disposed of through “annual ticket” arrangements that the waste contractor may agree with you for non-hazardous streams.

In any event, the UK Government’s current target, that at least 30% of batteries should be collected for appropriate treatment, is being exceeded, although some commentators suggest that a disproportionate amount relates to lead acid batteries (eg car batteries). For the waste manager, ensuring that operational controls are in place to check what has been put into streamed waste can be difficult. It is hard to tell, from a visual inspection into a deep, dark skip, whether some batteries are of a non-hazardous type or not.

Where mixed recycling is in place, delays and costs may arise with some waste contractors if batteries or other devices are found in the waste — remember some accumulators may look surprisingly like something that could come under WEEE Regulations! Occasionally, complex accumulators will do so.

In short, just throwing away batteries is not cost effective either in terms of business time or the environment.

Even for non-hazardous batteries, the general consideration about the progressive scarcity of landfill — and the costs of using it — makes going beyond compliance common sense. Many argue that even when general waste is being incinerated, batteries in the mix can lead to higher risks of air pollution (although there are specialised methods of incinerating certain battery materials — sometimes referred to as a pyrometallurgical process).

The illegal disposal of hazardous batteries, containing heavy metals for example, is simply dangerous in a landfill site, due to the risks of ground and water contamination; for example, from lead and mercury to name but a few. Where the FM has an educational role with tenants concerning recycling, then this is a message that they, in turn can pass onto their staff. This may help them be more cautious with disposal and understand the reasons why.

The strategies

These are some of the questions to be considered at site level.

  • Can the number of batteries used be reduced? Can longer life devices, such as accumulators, be used?

  • Does everyone understand the legal risks and environmental costs of sending batteries to landfill or incineration?

  • Do all producers of waste on site understand the legal and environmental reasons for regulations? Even if all tenants have their own duty of care arrangements, sharing recycling information and best practice may lead to a beneficial outcome for all.

  • Does the organisation know the different disposal options? Consider how they may impact on carbon reduction and other sustainable targets. Remember, the content of many batteries can be usefully recycled.

When replacing building systems, consider the most energy effective options for equipment needing batteries or accumulators; the most efficient method of recycling is to minimise the type and amount of waste that needs to be put into that process.

Where possible, define battery recycling targets for your own site and, where possible, encourage tenants to do the same. Where there is environmental or sustainability committee for a site, then the importance of battery recycling could be one topic for action.


There are probably more regulations on battery recycling to come. Yet the goal of better co-operation with stakeholders and supporting sustainability goals should be the main driver.