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6. Li Batt strategy – Companies’ own practices

Last Updated on 07/11/2023 by Sarah Sarsby

In advance of BHTA’s forthcoming guidance, companies should consider existing Li Batt Policy and End-of-Life Disposal practices. Within one’s own company and company value-chain, it is especially important to determine:

  • What processes already exist for consumers to return Li Batts via UK Government-mandated take-back/recycling schemes; and
  • Who – within the company value-chain – is responsible for operating this scheme.

This will require cooperation and collaboration between Manufacturers and Distributors/Retailers, as well as clear instructions to Consumers; per OPSS/DEFRA guidance:

  • “The manufacturer or importer that first places batteries on the UK market – including those in products – is classed as the producer and is therefore responsible for compliance if the business has a UK presence.
  • The only exception is the collection of Portable Batteries[i] – UK distributors and retailers that sell or supply more than 32 kg of batteries a year must provide a take back service [NB, batteries for mobility scooters and powered wheelchairs are Industrial Batteries, and fall outside this exception]
  • The guiding principles of [UK battery waste compliance] are that all waste batteries are processed by an Approved Battery Treatment Operator (ABTO) or an Approved Battery Exporter (ABE) and that producers pay for their collection, treatment and recycling. Distributors and retailers [per specific guidance] that sell or supply more than 32 kg of batteries a year must participate in the take back scheme. This involves providing a free collection point for waste portable batteries at their premises and arranging their transport to an ABTO or ABE, usually through a Battery Compliance Scheme.”

[i] Defined as “a battery or battery pack [that]:

  • Is sealed
  • Is not an Automotive or Industrial Battery
  • Can be hand-carried by an average natural person without difficulty”