1. 1
Position
Paper
Collection
Rate
according
to
the
Battery
Directive
1. The
Battery
Directive
The
battery
directive1
defines
the
‘collection
rate’
as
the
percentage
obtained
by
dividing
the
weight
of
waste
portable
batteries
and
accumulators
collected
in
a
calendar
year
by
the
average
weight
of
portable
batteries
and
accumulators
put
on
the
market
during
that
calendar
year
and
the
preceding
two
calendar
years.
According
to
this
directive,
Member
States
have
to
achieve
the
following
minimum
collection
rates:
(a)
25
%
by
26
September
2012;
(b)
45
%
by
26
September
2016.
Annex
1
of
the
Directive
gives
a
schematic
overview
of
the
reporting
calendar.
In
a
Decision2
of
2008,
the
European
Commission
defined
a
common
methodology
for
the
calculation
of
annual
sales
of
portable
batteries
to
end-­‐users.
In
2013,
the
Member
States
have
to
report
for
the
very
first
time
about
the
achieved
collection
rates.
The
concept
of
establishing
a
collection
target
for
the
waste
volume
in
relation
to
the
volume
placed
on
the
market
is
however
not
appropriate
for
(waste)
batteries.
The
lifespan
of
batteries
is
indeed
in
many
cases
much
longer
than
three
years,
so
there
is
no
strong
correlation
between
batteries
recently
put
on
the
market
and
the
waste
batteries
collected.
A
collection
target
can
only
be
adequate
if
it
is
related
to
the
quantities
of
waste
available
for
collection,
as
foreseen
in
the
new
WEEE
Directive3,
where
a
methodology
for
calculating
collection
rates
based
on
WEEE
generated
should
be
developed
in
the
near
future.
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
2
Commission
Decision
of
29
September
2008
establishing,
pursuant
to
Directive
2006/66/EC
of
the
European
Parliament
and
of
the
Council,
a
common
methodology
for
the
calculation
of
annual
sales
of
portable
batteries
and
accumulators
to
end-­‐users
3
Directive
2012/19/EU
of
the
European
Parliament
and
of
the
Council
of
4
July
2012
on
waste
electrical
and
electronic
equipment
(WEEE)

2. 2
2. Collection
Rate:
the
Eucobat
members
Eucobat
represents
following
compliance
organizations
for
batteries
(situation
01/01/2013):
Bebat
Belgium
Ecobat
Czech
Republic
elretur
Denmark
Recser
Oy
Finland
Screlec
France
GRS
Batterien
Germany
WEEE
Ireland
Ireland
Consorzio
Remedia
Italy
ARN
Netherlands
Stibat
Netherlands
Rebatt
Norway
Ecopilhas
Portugal
SNRB
Romania
Ecopilas
Spain
Taking
into
account
the
calculation
methodology
of
the
battery
directive,
the
Eucobat
members
achieved
following
collection
rates:
60,0%
50,0%
40,0%
30,0%
20,0%
10,0%
0,0%
Collection
Rate
Target
2012
Target
2016

3. The
representativity
of
the
compliance
organizations
differs
from
one
country
to
another.
Some
organizations
represent
the
whole
market
(Bebat,
Stibat),
while
other
compliance
organizations
represented
in
2012
only
a
minor
part
of
the
producers
(e.g.
SNRB).
A
general
remark
is
that
there
is
a
need
for
a
control
mechanism
to
determine
the
exact
total
weight
of
portable
batteries
put
on
the
market
in
case
of
more
than
one
compliance
organization
in
a
Member
State.
Almost
all
Eucobat
members
achieved
the
collection
target
for
2012
of
25%.
In
some
countries,
a
decrease
of
collection
and
collection
rate
is
a
consequence
of
a
decreasing
battery
market
(POM),
especially
for
alkaline
and
zinc
carbon
batteries.
In
this
position
paper,
we
will
develop
some
arguments
to
show
the
inadequacy
of
the
actual
collection
target,
and
we
will
explain
the
differences
in
the
collection
rate
of
the
member
organizations.
3
3. Elements
influencing
the
collection
rate
a. Lifespan
of
the
batteries
and
availability
for
collection
The
lifespan
of
batteries
is
in
many
cases
much
longer
than
three
years,
so
there
is
no
strong
correlation
between
batteries
recently
put
on
the
market
and
the
waste
batteries
collected.
This
lack
of
correlation
is
most
evident
for
the
rechargeable
batteries.
Their
lifespan
is
significant
longer
than
three
years,
in
particular
for
the
newer
chemistries
with
high
energy
density,
mainly
used
in
cordless
power
tools,
laptops
and
cell
phones.
Not
only
the
technical
lifespan
of
these
rechargeable
batteries
is
much
longer
than
3
years,
consumers
tend
to
keep
them
with
the
connected
appliance
even
after
the
appliance
has
been
replaced
(hoarding
effect).
To
a
certain
extent,
the
same
reasoning
is
valid
for
the
primary
batteries.
Thanks
to
the
growing
capacity
of
the
batteries
put
on
the
market
and
the
increasing
energy
efficiency
of
the
appliances
they
are
used
in,
the
technical
lifespan
of
the
primary
batteries
is
rising
each
year,
and
in
more
and
more
cases
exceeding
the
three-­‐year
period.
Furthermore,
given
the
extension
of
the
expiration
date
of
the
batteries
(up
to
7
years),
an
important
part
of
the
batteries
remain
in
the
drawer
for
a
long
time
before
they
are
effectively
used.

4. 4
Based
upon
a
study
of
Bebat
concerning
this
hoarding
effect,
the
collection
target
based
upon
the
average
amount
of
batteries
put
on
the
market
during
the
last
three
years
is
8,65%
higher
than
45%
of
the
volume
of
batteries
available
for
collection,
based
upon
the
life
cycle
distribution.
For
the
rechargeable
lithium
batteries,
with
an
increasing
volume
of
batteries
put
on
the
market
in
combination
with
long
lifecycle,
the
difference
between
the
volume
of
batteries
available
for
collection
and
the
average
volume
of
batteries
put
on
the
market
grows
significantly.
In
this
case,
the
target
of
45%
of
the
batteries
put
on
the
market
during
the
last
three
years
is
even
higher
than
the
batteries
available
for
collection.

5. Zinc/Carbon
-­‐
Alkaline
Lithium
Primary
Button
Cells
NiCd
NiMH
Lithium
Rechargeable
5
b. Evolution
of
the
battery
market
Since
2001,
the
number
of
rechargeable
lithium
batteries
put
on
the
market
increased
steadily
and
more
than
significantly.
The
impact
on
the
collection
rate
increases
each
year.
While
the
number
of
alkaline
/
zinc
carbon
batteries
put
on
the
market
has
decreased
with
10%,
the
number
of
rechargeable
lithium
batteries
put
on
the
market
has
been
multiplied
by
12
during
the
same
period,
as
shown
in
the
graph
below.
Batteries
put
on
the
market
per
chemistry
(Figures
Eucobat
-­‐
2001=100)
1400
1200
1000
800
600
400
200
0
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
There
are
no
indications
that
this
market
trend
would
change
in
the
near
future.

6. 6
As
a
consequence,
the
market
share
of
the
rechargeable
lithium
batteries
in
the
total
battery
mix
has
increased
dramatically.
Evolution
Portable
Battery
Mix
POM
(Figures
Eucobat)
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
c. WEEE
collection
rate
Many
batteries
are
discarded
together
with
the
appliance
they
were
used
in.
The
batteries
can
mainly
be
found
in
ICT
equipment
(laptops,
cell
phones,
….),
consumer
electronics
and
power
tools.
These
are
also
the
WEEE
categories
with
the
lowest
collection
rates
implying
that
there
are
but
few
batteries
that
may
be
collected
from
this
waste
stream.
While
generally
for
the
members
of
Eucobat,
the
batteries
put
on
the
market
integrated
in
an
appliance
represent
20-­‐35%
of
the
total
amount
of
batteries
put
on
the
market,
the
batteries
collected
from
the
WEEE
dismantlers
generally
only
represent
3-­‐9,5%
of
the
total
amount
of
collected
batteries.
Bebat
Ecobat
SNRB
Stibat
Batteries
POM
in
appliances
35,1%
20,0%
70,0%
25,4%
Batteries
collected
from
WEEE
dismantlers
4,6%
9,5%
20,0%
3,0%
0%
Lithium
Rechargeable
NiMH
NiCd
Button
Cells
Lithium
Primary
Zinc/Carbon
-­‐
Alkaline

7. 7
d. Removal
of
batteries
from
WEEE
According
to
the
WEEE
directive4,
batteries
may
be
removed
by
manual,
mechanical,
chemical
or
metallurgic
handling.
However,
only
the
batteries
removed
by
manual
handling
can
be
collected,
sorted
and
treated
in
an
environmental
sound
way.
As
a
consequence,
a
uniform
standard
for
the
depollution
of
WEEE
requiring
manual
removal
of
batteries
is
to
be
imposed
to
all
WEEE
operators
/
recyclers.
4. Collection
rate
per
chemistry
Due
to
the
elements
cited
before
(increased
lifecycle
/
lifespan,
removal
from
WEEE,
WEEE
collection
rates,
hoarding
etc.),
the
collection
rate
for
rechargeable
lithium
batteries
is
much
lower
than
for
the
other
chemistries.
This
leads
to
an
overall
lower
collection
rate
and
a
decreasing
potential
of
batteries
available
for
collection.
Collection
rate
per
chemistry
(Figures
Eucobat)
0%
20%
40%
60%
80%
Lithium
Rechargeable
Lead
Acid
NiMH
NiCd
Button
Cells
Lithium
Primary
Zinc/Carbon
-­‐
Alkaline
Collection
Rate
4
Directive
2012/19/EU
of
the
European
Parliament
and
of
the
Council
of
4
July
2012
on
waste
electrical
and
electronic
equipment
(WEEE)

8. 8
5. Differences
between
the
member
organizations
and
the
Member
States
a. The
impact
of
competition
There
is
a
correlation
between
the
number
of
compliance
schemes
in
a
member
state
and
the
achieved
collection
rate,
as
shown
by
the
following
graphic:
20
18
16
14
12
10
8
6
4
2
0
60,0%
50,0%
40,0%
30,0%
20,0%
10,0%
0,0%
Compliance
Organisation
Operational
Schemes
Eucobat
fully
adheres
to
the
principles
of
free
competition,
but
a
higher
number
of
collection
schemes
increases
the
risk
of
unfair
competition.
A
level
playing
field
with
uniform
standards
for
all
actors
is
required
to
ensure
fair
competition.
There
is
a
need
for
a
control
mechanism
to
guarantee
that
all
discarded
batteries,
including
the
negative
value
stream,
are
collected
and
that
cherry
picking
is
avoided.
The
efforts
of
competing
schemes
to
collect
the
batteries
at
the
lowest
costs,
and
the
focus
on
high
performing
collection
points
prevents
the
nationwide
service
for
all
collection
points,
e.g.
in
poorer
populated
regions.
A
nationwide
coordination
is
required
in
order
to
optimize
the
effectiveness
of
consumer
awareness
measures
and
the
provision
of
sufficient
collection
points
for
users,
and
to
ensure
the
take-­‐back
of
waste
batteries
from
all
entities
that
collect
them
without
distorting
the
competition
between
the
schemes.
b. Interpretation
of
definitions
The
producers
can
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,
which
is
one
of
the
criteria
of
these
definitions.

9. It
is
however
much
more
difficult
for
the
operational
actors
to
apply
these
definitions,
as
they
only
receive
the
batteries
and
battery
packs,
without
knowing
the
applications
they
were
used
in.
They
are
obliged
to
use
a
set
of
criteria
that
differs
from
country
to
country.
The
different
interpretations
in
the
Members
States
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.
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.
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
collected
batteries
above
3
kg
that
cannot
be
used
by
private
households
are
considered
industrial
batteries.
9
c. General
consumer
awareness
towards
waste
There
is
a
strong
correlation
between
the
general
consumer
awareness
towards
waste
and
the
battery
collection
rate.
The
member
states
where
the
part
of
the
sorted
ordinary
waste
in
the
total
waste
is
higher5,
are
also
the
countries
where
the
compliance
schemes
achieve
the
highest
collection
rates
for
batteries.
70,0%
60,0%
50,0%
40,0%
30,0%
20,0%
10,0%
0,0%
60,0%
50,0%
40,0%
30,0%
20,0%
10,0%
0,0%
Bebat
Consorzio
Remedia
Ecobat
Ecopilas
Ecopilhas
Elretur
GRS
Recser
Oy
Screlec
SNRB
Stibat
WEEE
Ireland
Collection
Rate
Batteries
Sorted
Ordinary
Waste
5
Calculation
based
upon
the
Eurostat
figures
concerning
the
Total
Waste
and
the
Unsorted
Waste.

10. 10
6. Alternative
methodologies
A
collection
target
can
only
be
adequate
if
it
is
related
to
the
quantities
of
waste
available
for
collection.
This
concept
has
already
been
integrated
in
the
new
WEEE
Directive6,
where
a
methodology
for
calculating
collection
rates
based
on
WEEE
generated
should
be
developed
in
the
near
future.
This
methodology
allows
taking
into
account
the
differing
life
cycles
of
the
batteries
and
of
the
appliances
they
are
used
in,
as
well
as
the
market
situation
and
saturation.
It
requires
however
the
obligation
for
all
actors
to
report
to
the
national
authorities
and
the
obligation
for
the
member
states
to
monitor
all
waste
streams.
The
producers
remain
responsible
for
accepting
all
waste
batteries
handed
over
to
them.
7. About
Eucobat
Eucobat
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
6
Directive
2012/19/EU
of
the
European
Parliament
and
of
the
Council
of
4
July
2012
on
waste
electrical
and
electronic
equipment
(WEEE)