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6. Li Batt strategy – Companies’ own practices

6. Li Batt strategy – Companies’ own practices

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”

5. Li Batt support – Consumer to retailer

5. Li Batt support – Consumer to retailer

Encourage consumers to ask questions about the policies and practices your company has in place to ensure the safe handling, storage, and disposal of Li Batts by you as a retailer and your staff. Be prepared to explain how you approach:

  • Lithium Battery Safety Training
  • Battery Inspection and Testing
  • Appropriate Battery Chargers for Private Use
  • Safe Charging Stations for Public Use (if applicable)
  • Battery Capacity Disclosure at Point of Sale
  • Battery Disposal and Recycling
  • Transportation Guidelines – no Li Batt of any capacity over 100Wh/4Ah should be transported as anything other than Dangerous Goods; other traditional batteries – e.g. spillable, sealed lead acid (SLA), absorbent glass matt (AGM), or gel – may be shipped as non-Dangerous Goods provided they are undamaged, clean, and have their terminals protected; always check with the battery manufacturer for recommended transport modes
  • Storage and Shelf Life
  • Battery Safety Information
  • Recall Management – Product Registrations and Staying Informed
  • Incident Reporting and Investigation

3. Not all Li Batts are the same

3. Not all Li Batts are the same

Li Batts come in several different types, or chemistries. This guidance does not seek to describe all Li Batt types, and any Li Batts of any chemistry should be treated with special care due to unique safety factors that make them different from other, more traditional battery technologies (see Sections 7-8 for more detail). Between two of the most commonly-used Li Batt chemistries in health and social care (H&SC) devices (e.g. mobility scooters, powered wheelchairs, stairlifts), it is important to note several distinctions.

Lithium nickel / manganese / cobalt oxides (Li-NMC)

Li-NMC Batts are mixed-metal oxides of lithium, nickel, manganese and cobalt, commonly used in lithium-ion batteries (as cathode material) for mobile devices and electric vehicles (aluminum is also sometimes found in Li Batts of this type). Li-NMC Batts are among the lightest, most efficient, and most energy-dense chemistries, and their use is widespread.

Key Li-NMC Batt components (nickel, manganese, and cobalt), however, are expensive, supply-constrained, and subject to both human-rights and environmental concerns. Moreover, when Li-NMC Batts are damaged – due to improper charging, short-circuit, impact damage, or crush damage – they can produce very dangerous conditions including:

  • Release of toxic gases
  • Extremely energetic and hard-to-extinguish fires (see Section 8 for a more detailed description of materials combustibility, including “thermal runaway”)
  • Explosions
Lithium battery image

Lithium ferro-phosphate, sometimes aka lithium iron phosphate (LiFePO4)

A LiFePO4 Batt is a type of lithium-ion battery using lithium iron phosphate as the cathode material, and a graphitic carbon electrode with a metallic backing as the anode. Compared to Li-NMC, LiFePO4 chemistry yields a battery that is 20 percent heavier, less energy-dense, and sometimes more expensive (due in part to it being less widely used currently).

Unlike Li-NMC, however, LiFePO4’s non-lithium components (iron and phosphate) are much more common in the Earth’s crust – and they last longer (c. 1,000 – 2,500 cycles) than Li-NMC (c. 650 – 1,000 cycles); see Section 7 for a more detailed description of cycle life.  Most importantly, compared to other Li Batt chemistries[i], LiFePO4 Batts have significant safety advantages:

  • Much greater thermal and chemical stability – in part due to the absence of flammable electrolyte in LiFePO4 Batts – which reduces significantly the risk of “thermal runaway”
  • Greater physical and structural stability, which reduces the risk of impact damage or crush damage
  • Greater chemical durability and resilience, which reduces the risk of fire/explosion in the event of mishandling (due to physical damage or improper charge damage) and increases battery stability across a greater range of atmospheric temperatures

[i] For more detail, please see the ‘Comparison to other battery types’ section of the Lithium iron phosphate battery Wikipedia page [accessed 13-Oct-23].

1. Introduction

1. Introduction

As the UK’s industry representative for assistive technology in the health & social care sector (H&SC), the British Healthcare Trades Association (BHTA) and its members are committed to helping people live healthier, more independent lives. Our member-companies do this by providing safe, effective, and environmentally responsible technologies – the right products and services, at the right time, and the right value.

Like other products powered by rechargeable batteries, mobility scooters, powered wheelchairs, and homelifts increasingly feature Lithium Battery (Li Batt) technology. BHTA has been asked by its members to highlight safe practices for use, maintenance, and disposal of Li Batts. 

Working with industry, policy-makers, and environmental advisors, BHTA is assembling B2B guidance for each of the participants in the Li Batt lifecycle – manufacturers, distributors, and retailers[i]. Given Li Batts’ unique health & safety and environmental risks, however, we are publishing immediately this B2C guidance for retailers to provide to consumers.


[i] This guidance will comprise five parts; the first two will support assistive technology companies that make, sell, or use Li Batts with their own practices; the final three will define processes and responsibilities between the four parties with a stake in Li Batt lifecycle responsibility (Manufacturers, Distributors, Retailers, Consumers).  The five parts – and the topics covered in each – are:

  1. Policy
  2. End-of-Life Disposal
    • Objectives
    • Scope
    • Definitions
    • Reference
    • Risk Assessment
    • Procedures
    • Work-Flow Diagram
  3. Manufacturers & Distributors/Retailers
  4. Distributors/Retailers & Consumers (sales and aftercare)
  5. Consumers & Manufacturers/Distributors/Retailers (battery recycling and end-of-life disposal)
    • Safe Use & Maintenance
    • Marking
    • Packaging
    • Labelling
    • Transport
    • Damaged Goods
    • References (UK regulations)
    • Specialist Packaging