Guidance

Storing lead acid batteries, cable and gas cylinders at household waste recycling centres (HWRCs): RPS 308

Published 11 September 2024

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to comply with an environmental permit for a waste operation when your HWRC accepts:

• lead acid vehicle batteries coded 16 06 01*
• cable coded 16 02 15,16 02 16, 17 04 10 or 17 04 11
• gas cylinders coded 16 05 04*

(*) An asterisk at the end of a code means the waste is hazardous.

However, the Environment Agency will not normally take enforcement action if you do not comply with this legal requirement provided that:

• your activity meets the description set out in this RPS
• you comply with the conditions set out in this RPS

In addition, your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest

1. Activity this RPS applies to

This RPS applies to HWRCs accepting:

• lead acid vehicle batteries coded 16 06 01* where the permit lists 20 01 33* as a waste that can be accepted
• pressurised gas cylinders coded 16 05 04* where the permit lists 16 05 05 as a waste that can be accepted
• waste electronic and electrical equipment (WEEE) cable coded 16 02 15* or 16 02 16, and waste electrical and telecommunications (non-WEEE) cable coded 17 04 10* or 17 04 11 – it does not allow any cables containing oils or coal tar

2. Conditions you must comply with

You must operate a HWRC site with an environmental permit.

To accept lead acid vehicle batteries coded 16 06 01, your permit must include 20 01 33 (batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and unsorted batteries and accumulators containing these batteries).

To accept pressurised gas cylinders coded 16 05 04*, your permit must include 16 05 05 (gases in pressure containers other than those mentioned in 16 05 04).

To accept cable coded 16 02 15* or 16 02 16, and 17 04 10* or 17 04 11, your permit must include either:

• 20 01 35* (discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components)
• 20 01 36 (discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35)

You must keep records for 2 years to show that you have complied with this RPS and make these records available to the Environment Agency on request.

Lead acid batteries must be:

• stored in secure containers that are leak-proof with an impermeable, acid resistant base
• stored in closed containers or under cover to prevent the accumulation of rainwater

Gas cylinders must be:

• stored in secure storage cages that are well ventilated and constructed of non-combustible materials which provide shading against direct sunlight
• segregated so that those that have flammable contents are stored in separate cages to those with oxidising contents
• segregated so that non-waste gas cylinders are clearly identified and stored separately from waste gas cylinders
• stored upright with seals and protection caps in place where provided

You must not:

• stack gas cylinders
• store batteries or gas cylinders with other wastes
• mix any WEEE cable with waste electrical and telecommunications (non-WEEE) cable
• mix any plastic from WEEE cable with plastic from waste electrical and telecommunications (non-WEEE) cable
• store these wastes for longer than 6 months

3. Things to note

Waste classification guidance for lead acid vehicle batteries from households states they must be coded 16 06 01. We are aware that some HWRC permits currently only have waste code 20 01 33 (batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and unsorted batteries and accumulators containing these batteries).

Not all gas cylinders are waste. Branded cylinders are often collected by the producer or supplier company and refilled. Storing these cylinders pending collection would not be a waste activity provided the cylinders are:

• designed to be reused
• returned to the supplier for refilling

We are aware that HWRCs currently accept pressurised gas cylinders under a non-hazardous waste code 16 05 05, but that many do not have the corresponding hazardous waste code 16 05 04*. This RPS will allow them to accept pressurised gas cylinders that are hazardous due to their residual contents.

There’s more guidance on gas cylinder storage in the Waste Industry Safety and Health (WISH) Forum’s Orphaned gas cylinders in the waste and recycling industries.

We will update permits to include waste codes 16 02 15, 16 02 16, 17 04 10, 17 04 11, 16 06 01* and 16 05 04* through permit reviews and by updating the current standard rules permits.  

4. When you must check back

The Environment Agency intends to review this RPS by 30 June 2027.

The Environment Agency can withdraw or amend this regulatory position before the review date if they consider it necessary. This includes where the activities that this RPS relates to have not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

5. If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must:

• stop the activity to which this RPS relates
• tell the Environment Agency immediately by emailing enquiries@environment-agency.gov.uk

6. Contact the Environment Agency

If you have any questions about this RPS email enquiries@environment-agency.gov.uk