At the ICBR 2014, Eucobat presented her priorities for the upcoming Batteries Directive review.

1. Priorities for the
Battery Directive Revision
Hamburg – September 24th 2014

2. 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

3. 1. Eucobat
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

4. 2. Distinction Portable-Industrial-Automotive
• 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

5. 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)

6. 2. Distinction Portable-Industrial-Automotive
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”

7. 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

8. 4. Relationship Other EPR schemes
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.

9. 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.

10. 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

11. 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.

12. 7. Batteries in WEEE
• 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)

13. 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

14. 7. Batteries in WEEE
• 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.

15. 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.

16. 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

17. 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.

18. 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.

19. 9. Information requirements
• 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.

20. 9. Information requirements
• 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.

21. 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

22. Thank you for your attention