Distinction Portable-Industrial-Automotive - Eucobat Position

1. Position
Paper
Distinction
Portable
–
Industrial
–
Automotive
Batteries
1. The
Battery
Directive:
actual
situation
The
battery
directive1
distinguishes
following
types
of
batteries:
• Portable
battery
or
accumulator’
means
any
battery,
button
cell,
battery
pack
or
accumulator
that:
o is
sealed;
and
o can
be
hand-­‐carried;
and
o is
neither
an
industrial
battery
or
accumulator
nor
an
automotive
battery
or
accumulator.
• Industrial
battery
or
accumulator’
means
any
battery
or
accumulator
designed
for
exclusively
industrial
or
professional
uses
or
used
in
any
type
of
electric
vehicle.
• Automotive
battery
or
accumulator’
means
any
battery
or
accumulator
used
for
automotive
starter,
lighting
or
ignition
power.
This
distinction
is
important,
as
it
is
decisive
to
determine
the
liabilities
and
responsibilities,
as
well
operational
as
financial,
of
all
concerned
actors.
In
particular,
the
significance
of
the
classification
of
the
batteries
is
undisputable
for
the
calculation
of
the
collection
target,
as
this
only
applies
to
portable
batteries.
After
several
years
of
experience
in
the
Member
States,
it
seems
that
there
is
particularly
a
problem
to
distinguish
industrial
from
portable
batteries.
2. Current
application
of
the
definitions
For
the
batteries
put
on
the
market,
the
decision
on
the
classification
is
taken
by
the
producers,
based
upon
a
decision
tree
that
is
explicitly
or
tacitly
approved
by
the
Member
State
and
that
takes
into
account
the
criteria
described
in
the
battery
directive.
The
decision
trees
used
in
the
different
Member
States
are
similar,
with
to
a
larger
or
smaller
extent
some
interpretative
guidance
for
the
producers
on
the
different
criteria.
1
Directive
2006/66/EC
of
the
European
Parliament
and
of
the
Council
of
6
September
2006
on
batteries
and
accumulators
and
waste
batteries
and
accumulators
and
repealing
Directive
91/157/EEC
–
Article
3,
3°-­‐5°-­‐6°

2. For
the
collected
batteries,
the
operational
actors,
e.g.
sorting
or
recycling
facilities,
take
the
decision
on
the
classification.
As
one
of
the
criteria
to
distinguish
industrial
batteries
from
portable
batteries
is
the
intended
use
of
these
batteries
(“designed
for
exclusively
industrial
or
professional
uses”),
and
it
is
impossible
for
these
operational
actors
to
know
2
the
use
of
the
collected
battery,
they
use
other
criteria,
like:
• Weight
(varying
per
country
from
1kg
to
5
kg)
• Collection
point
(industrial
collection
points
or
consumer
collection
points)
• Pro
rata
(proportion
industrial
–
portable
batteries
is
the
same
for
collection
as
for
POM)
• Sample
• …
• A
mix
of
these
criteria
3. Issues
concerning
the
criteria
The
producers
can
relatively
easily
apply
the
definitions
of
the
battery
directive,
as
they
know
in
most
cases
the
intended
use
of
the
batteries
they
put
on
the
market.
It
is
however
much
more
difficult
for
the
operational
actors
to
apply
these
definitions,
as
they
only
receive
the
waste
batteries
and
battery
packs,
without
knowing
the
applications
they
were
used
in.
They
are
obliged
to
use
a
set
of
criteria
(see
above)
that
differs
from
country
to
country.
The
different
interpretations
in
the
Members
States
for
the
classification
of
the
waste
batteries
into
industrial
and
portable
waste
batteries
have
a
serious
impact
on
the
reported
collection
rates.
As
a
consequence,
these
differences
make
it
very
difficult
to
compare
the
figures
of
the
Member
States.
Furthermore,
experience
shows
that
the
application
of
inappropriate
criteria
to
distinguish
the
collected
batteries
leads
to
unrealistic
collection
rates
in
some
Member
States.
Besides
the
collection
rates,
the
interpretation
also
influences
the
financing
of
the
collection
schemes
in
the
Member
States
where
multiple
compliance
organizations
coexist.

3. 3
4. Eucobat
proposal
The
main
criterion
to
distinguish
portable
batteries
from
industrial
batteries
in
the
definitions
of
the
battery
directive
is
of
intentional
kind
(“designed
for
exclusively
industrial
or
professional
uses”),
which
cannot
be
determined
when
the
batteries
are
collected.
A
full
coherence
in
the
classification
of
the
batteries
put
on
the
market
and
the
collected
batteries
can
for
this
reason
only
be
achieved
by
a
fundamental
review
of
these
definitions.
We
are
convinced
that
this
will
be
necessary
on
the
moment
of
the
recast
of
the
battery
directive
and
we
will
discuss
this
point
within
Eucobat
and
will
formulate
a
proposal.
An
intermediate
solution,
standing
the
current
definitions,
is
required
to
ensure
the
comparability
of
the
reported
figures
of
the
Member
States,
with
a
clear
guidance
that
is
easily
applicable
for
the
producers
and
for
the
operational
actors.
As
indicated,
the
producers
can
relatively
easily
apply
the
current
definitions
for
the
batteries
they
put
on
the
market,
using
the
existing
decision
trees.
On
the
other
hand,
clear
interpretation
guidance
is
required
for
the
operational
actors
for
the
collected
batteries,
in
order
to
ensure
that
these
operational
actors
classify
the
batteries
in
the
same
way
as
declared
by
the
producers.
In
order
to
distinguish
portable
batteries
from
industrial
waste
batteries,
the
experience
of
the
compliance
schemes
indicates
that
a
weight
limit
of
3
kg
corresponds
to
a
certain
reality
and
could
be
used
as
a
first
criterion.
This
appears
clearly
from
a
sample
in
three
countries
on
a
typical
general
household
mix
of
waste
batteries
collected
by
the
compliance
organisations
in
those
countries.
The
figures
indicate
that
a
large
majority
of
the
collected
batteries
from
households
have
a
weight
till
3
kg.
6a. Definitions P-I-A: Sampling
Definitions P-I-A: Sampling
Weight&per&ba7ery&
(kg)& Number&Ba7eries Total&&Weight
0,00&W&1,00& 43% 17%
1,01&W&2,00& 16% 15%
2,01&W&3,00& 27% 35%
3,01&W&4,00& 5% 8%
4,01&W&5,00& 2% 4%
5,01&W&…& 6% 21%
6a. Definitions 87%& 67%&
P-I-A: Sampling
(kg)' Number'Ba,eries Total''Weight
100% 100%
Belgium&
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00& 96,6%&
1,01&W&2,00& 1,2%&
2,01&W&3,00&
3,01&W&4,00& 2,1%&
4,01&W&5,00&
5,01&W&…&
100,0%&
97,8%&
Germany&
0,00';'1,00' 43% 17%
1,01';'2,00' 16% 15%
2,01';'3,00' 27% 35%
3,01';'4,00' 5% 8%
4,01';'5,00' 2% 4%
5,01';'…' 6% 21%
87%' 67%'
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00&
1,01&W&2,00& 99,9%&
2,01&W&3,00&
3,01&W&4,00&
4,01&W&5,00& 0,1%&
5,01&W&…&
100,0%&
Netherlands&
ba7ery&
Number&Ba7eries Total&&Weight
43% 17%
16% 15%
27% 35%
5% 8%
2% 4%
6% 21%
100% 100%
87%& 67%&
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00& 96,6%&
1,01&W&2,00& 1,2%&
2,01&W&3,00&
3,01&W&4,00& 2,1%&
4,01&W&5,00&
5,01&W&…&
100,0%&
97,8%&
Germany&
Weight'per'ba,ery'
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00&
1,01&W&2,00& 99,9%&
2,01&W&3,00&
3,01&W&4,00&
4,01&W&5,00& 0,1%&
5,01&W&…&
100,0%&
Netherlands&
100% 100%
Belgium'
Weight'per'ba,ery'(kg)! Number'of'ba,eries! Total'Weight!
0,00';'1,00' 96,6%'
1,01';'2,00' 1,2%'
2,01';'3,00'
3,01';'4,00' 2,1%'
4,01';'5,00'
5,01';'…'
100,0%'
97,8%'
Germany'
Weight'per'ba,ery'(kg)! Number'of'ba,eries! Total'Weight!
0,00';'1,00'
1,01';'2,00' 99,9%'
2,01';'3,00'
3,01';'4,00'
4,01';'5,00' 0,1%'
5,01';'…'
100,0%'
Netherlands'

4. 4
However,
this
weight
criterion
is
not
absolute,
as
some
batteries
of
more
than
3
kg
that
are
typically
used
by
consumers
and
that
can
be
separated
based
upon
the
collection
channel,
should
be
considered
as
portable.
In
order
to
ensure
that
the
collected
batteries
are
classified
in
the
same
way
as
the
batteries
put
on
the
market
declared
by
the
producers,
Eucobat
proposes
that
the
batteries
above
3
kg
that
cannot
be
used
by
private
households
are
considered
industrial
batteries.
5. About
Eucobat
Eucobat
aisbl
is
the
European
association
of
national
collection
schemes
for
batteries.
They
assure
that
all
waste
batteries
are
collected
and
recycled
in
an
ecological
sound
way,
and
contribute
this
way
to
a
better
environment.
Eucobat
aisbl
October
2013