Last reviewed 3 October 2022

Dr Lisa Bushby provides guidance on the correct procedures for the handling, disposal and treatment of waste batteries.


With the proliferation of consumer electronics and the trend towards wireless tools and equipment, batteries are an essential element of many everyday domestic products and are ubiquitous in the workplace with approximately 800,000t of automotive batteries, 190,000t of industrial batteries and 160,000t of consumer batteries entering the EU annually.

However, while many of the components of batteries are recyclable, not all are properly collected and recycled at the end of their life, which increases the risk of hazardous substances being released into the environment and constitutes a waste of resources, contrary to the concept of a circular economy.

Accordingly, the Waste Batteries and Accumulators Regulations 2009 (as amended) set out the requirements for waste battery collection, treatment, recycling and disposal for all battery types. The regulations affect producers, battery distributors (retailers), waste battery collectors, recyclers and exporters.

First and foremost, all batteries must be labelled with the crossed-out wheeled bin, which indicates that batteries should not be thrown away with other waste — they should be collected separately.

Second, the regulations refer to three types of battery.

  1. Portable: sealed, weighs less than 4kg, and not industrial or automotive.

  2. Automotive: starts a vehicle engine, powers a light vehicle.

  3. Industrial: designed exclusively for industrial or professional use, powers an electric or “hybrid” vehicle, unsealed, but not automotive.

Workers’ health and safety

These types of batteries can contain hazardous substances, notably lead-acid, sulphuric acid or potassium hydroxide, can be heavy, and can constitute a fire risk, therefore before recycling or disposal options can be considered, these risks need to be controlled so workers handling batteries can do so safely.

Avoid exposure to corrosive substances by:

  • wearing gloves and suitable eye protection

  • wearing a plastic apron and suitable boots.

Ensure an unwanted circuit isn’t created by:

  • emptying pockets of any metal objects that could fall onto the battery or bridge across its terminals

  • fitting temporary plastic covers over the battery terminals

  • using suitable single-ended tools with insulated handles

  • not wearing a watch, ring, chain, bracelet or other metal item.

Avoid fire risks by:

  • keeping sources of ignition well away from batteries that are being charged, have recently been charged or are being moved

  • not smoking

  • charging in a well-ventilated area and stop charging as soon as the battery is fully charged.

Manual handling risks can be reduced by sharing the load when lifting batteries and check there are no trip or slip hazards around.

Producer and distributor obligations

Battery producers and distributors have different obligations under the regulations.

Producers that place more than 1t of portable batteries onto the UK market must:

  • register with a compliance scheme

  • complete data submissions detailing the amount of batteries you have placed onto the UK market

  • pay a share towards the costs of battery recycling.

Battery compliance schemes include those operated by Valpak or Veolia who take on the responsibility for:

  • registering annually with the correct environmental regulator

  • paying the environmental regulator £600 annually

  • sending information to the environmental regulator about the batteries placed on the market in the previous two years and the current year

  • getting evidence notes for the collection, treatment and recycling of waste portable batteries

  • sending information to the environmental regulator about the waste batteries they collect and deliver for treatment and recycling.

Producers that place 1t or less of portable batteries onto the UK market must:

  • register directly with the Environment Agency (EA)

  • complete an annual data submission detailing the amount of batteries you have placed onto the UK market.

Distributors who sell over 32kg of batteries per year per store must:

  • offer in-store collection for portable batteries

  • publicise at point of sale that a battery recycling point is available in-store.

These obligations are not to be taken lightly. In 2015, Babz Media Ltd, an online trading company, was fined £45,000 for non-compliance with the packaging, batteries and WEEE regulations after pleading guilty to failing to register with the EA and a producer compliance scheme to ensure compliance with all three waste regulations. Babz Media also pleaded guilty to avoiding the cost of financing the collection and recycling of packaging, electrical equipment and batteries between 2011 and 2014.

Transport of waste batteries

Waste batteries, eg scrap lead acid batteries from vehicles (UN 2794), may be carried in bulk subject to the conditions set out in the Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR), which applies in full as there is no minimum load for bulk carriage. If drivers carrying waste batteries in bulk do not have a valid ADR certificate a deferred prohibition notice is appropriate, and the carrier should be asked to confirm arrangements for training.

Treatment of waste batteries

Once at a treatment facility, the processing of waste batteries and accumulators raises several environmental concerns, largely as a result of their metal content. Mercury, lead and cadmium are by far the most problematic of these substances, and so there are limits on the per cent content of these heavy metals in batteries.

  • No battery may contain 0.002% of cadmium by weight unless labelled Cd. This requirement does not apply to portable batteries used in emergency lighting and alarm systems, cordless power tools placed on the market before 1 January 2017 and industrial and automotive batteries.

  • No battery or accumulator on the market may contain more than 0.0005% of mercury by weight, unless the battery is a button cell and marked Hg. In such cases, the limit is 2% by weight.

  • Batteries cannot contain more than 0.004% of lead by weight unless marked Pb.

Lead batteries, nickel-cadmium batteries and batteries containing mercury are all classified as hazardous waste. Other metals commonly used in batteries, such as zinc, copper, manganese and lithium, may also have associated environmental hazards. For example, when batteries are incinerated, the metals they contain pollute the atmosphere and the incineration residues. When batteries end up in landfills, metals can leach into the soil and water.

Lead, for instance, can be released at all stages of the recycling process. Draining the lead-contaminated electrolyte, or its leakage, can contaminate soil and water bodies. Breaking up the battery mechanically or manually releases lead particles and contaminated mist and dust. Smelting the lead components generates hazardous lead fumes.

However, lead is a cumulative toxicant that affects multiple body systems including the neurological, haematological, gastrointestinal, cardiovascular, reproductive and renal systems. Chronic lead exposure is associated with an increased risk of hypertension and renal disease. Severe lead poisoning, whether from acute or chronic exposure, can be fatal.

Accordingly, lead-acid battery recycling should only take place at facilities that are equipped with engineering controls to minimise lead emissions, including fully automated and enclosed operations, adequate exhaust systems with air filtering technology and effluent treatment systems.

Furthermore, workers at recycling facilities should be trained and provided with appropriate personal protective equipment, and facilities for washing and changing into clean clothes. There should be a programme for monitoring workers’ exposure and the application of corrective measures if exposure standards are exceeded.

Policy recommendations

  • Recycling lead-acid batteries should be a regulated industry, with standards set, monitored and enforced for the location and operation of recycling plants.

  • Informal or unlicensed battery recycling should be prohibited.

  • Ways for discouraging informal recycling include promoting the collection of used batteries by licensed retailers when replacement batteries are being bought, manufacturer take-back schemes.

  • Communities should be informed about the hazards of informal lead-acid battery recycling.


When using batteries, it is important to follow all of the regulations, for example when transporting batteries and also at their end-of-life, following waste requirements. Be aware that batteries contain hazardous substances and so steps should be taken to ensure the protection of workers. If in doubt seek expert help.