Waste batteries: appropriate measures for permitted facilities

1. When appropriate measures apply

An introduction to the standards (appropriate measures) that apply to regulated facilities permitted under the Environmental Permitting Regulations to treat or transfer separate collections of waste batteries.

These appropriate measures apply to regulated facilities including those operated by:

• approved battery treatment operators (ABTOs)
• approved battery exporters (ABEs)

ABTOs and ABEs are also subject to additional requirements under the Waste Battery and Accumulators Regulations – see section 1.3 ‘Waste Batteries and Accumulators Regulations (WBAR)’ on this page.

For the purpose of this guidance, waste batteries include:

• battery packs, modules and cells
• similar wastes from battery manufacturers (for example, off-specification or unused batteries or cells)

Separate technical permitting guidance applies to regulated facilities that treat or transfer other types of waste.

If you store or treat waste batteries at a permitted facility that handles other types of waste (for example at a metal recycling site, transfer station or household waste recycling centre) the relevant parts of this guidance will apply to your waste batteries activities.

The guidance applies to the management of separate collections of waste batteries (including collections of mixed batteries).

It does not apply to the management of other wastes that may contain waste batteries (for example, mixed municipal wastes or waste electrical and electronic equipment (WEEE)).

Where regulated facilities produce separate collections of waste batteries from on-site activities (for example, from the treatment of mixed wastes or WEEE) the relevant parts of this guidance will apply.

The guidance does not apply to exempt waste activities. For example, premises that provide collection points for household batteries and other exempt waste facilities. However, exempt waste facilities may find it useful to refer to relevant parts of the guidance.

This guidance includes measures for the storage and handling of wastes resulting from waste battery treatment activities and controlling associated emissions. However, it does not cover the further treatment of these wastes, such as:

• the treatment of black mass (a material recovered from battery electrodes containing metals, such as nickel, cobalt and lithium) using hydrometallurgical or pyrometallurgical processes
• the treatment other chemical wastes, such as electrolytes or solvents

Similarly, it does not cover the production of secondary metals from battery waste. For example, the smelting of lead from lead acid batteries or other smelting and refining activities regulated as non-ferrous metal sector activities.

Where such treatment activities are undertaken at regulated facilities, other technical guidance for regulated industry sectors will apply where relevant. For example, our:

• Chemical waste appropriate measures guidance
• Inorganic chemicals sector: additional guidance
• Non-ferrous metals and the production of carbon and graphite: additional guidance

If waste batteries are stored, handled or treated at these facilities, the relevant parts of this guidance will apply to these waste batteries activities.

Separate collections of waste battery electrolyte and other chemical wastes (for example, acids, solvents, other liquids, slurries or sludges) must be managed in accordance with the relevant requirements of our Chemical waste appropriate measures guidance.

Combustion plant with a rated thermal input between 1 megawatt and 50 megawatts must comply with the relevant requirements of the Medium Combustion Plant Directive. Specified generator controls, unless excluded, apply to generators with a rated thermal input of up to 50 megawatts. See our guidance on medium combustion plant and specified generators.

1.1 When appropriate measures apply

There is a lot of overlap between:

• best available techniques (BAT) for waste installations facilities
• necessary measures for waste operation facilities

The Environment Agency uses the term ‘appropriate measures’ to cover all these requirements. Appropriate measures are the standards that operators should meet to comply with their environmental permit requirements. This guidance sets out what you must consider when you assess the appropriate measures for your site. It is not definitive, and it does not replace your obligation to assess appropriate measures fully for your site, considering its location and other site-specific characteristics.

Where measures are specified for waste batteries, these measures are in addition to any applicable measures set out in the general waste storage or treatment sections of this guidance.

The appropriate measures in this technical guidance have been grouped into the following sections:

• general management
• waste pre-acceptance, acceptance and tracking
• waste storage, segregation and handling
• waste treatment
• emissions control
• emissions monitoring and limits
• process efficiency (measures for using energy, raw materials and water apply to Industrial Emissions Directive (IED) installations only)

Some measures may not be suitable or relevant for your operation. Relevant appropriate measures will depend on the:

• activities being carried out
• size and nature of the activities
• location of the site

For installations there are additional requirements for using energy and raw materials (including water) efficiently. These are called process efficiency measures.

Where a measure is not suitable, you can propose alternative measures that achieve the same level of environmental protection. Or you can provide an explanation of why the specific measure is not relevant to your operations.

In certain situations, you may need to provide a higher standard of environmental protection, for example:

• where there are local sensitive receptors
• if there is a risk that an operation may exceed an Environmental Quality Standard

This guidance also covers some activities where legislation applies directly to that activity. This guidance and any time scales for the appropriate measures does not remove the need to comply with that legislation. For example, legislation relating to persistent organic pollutants or hazardous waste.

1.2 Implementing appropriate measures at new and existing facilities

The appropriate measures in this guidance apply to both new and existing facilities that treat or transfer waste batteries.

For new facilities, the appropriate measures must be in place before operations start.

For existing facilities, if the cost of complying with the appropriate measures is disproportionate to the environmental benefit, immediate compliance may not be reasonable.

Through permit reviews, the Environment Agency will assess the current operating techniques of existing facilities against the relevant appropriate measures.

Where an operator is not using appropriate measures, we will expect them to provide improvement plans and timetables for implementing the relevant appropriate measures. We will review these proposals and set formal timescales for making the improvements needed. We will do this by varying the environmental permit to include improvement conditions.

Improvements at existing facilities are likely to fall into one of the following 2 categories.

Standard good practice requirements

For example, these could be:

• updated management systems
• waste, water and energy efficiency measures
• measures to prevent fugitive or accidental emissions
• waste acceptance and handling techniques
• appropriate monitoring equipment

Where these improvements are relatively low cost, operators must implement them as soon as possible and in any event within 12 months.

Larger, more capital-intensive improvements

For example, these could be:

• installing significant abatement equipment
• the significant redesign of facility layout, including the design and installation of new buildings or treatment plant

Operators should complete these improvements as soon as practicable and in any event within 3 years.

Local environmental impacts may mean you need to act more quickly than the timescales provided here. For example, if there are sensitive receptors or an air quality management area close by.

Relevant BAT associated emission levels (AELs) apply to existing installation facilities from August 2022, unless we approve a derogation. BAT AELs are set out in the published waste treatment BAT conclusions.

New installations (including new or replacement plant at existing facilities or a substantial change to existing plant) must comply with any relevant BAT AELs from when operations begin, unless a derogation is approved.

1.3 Waste Batteries and Accumulators Regulations (WBAR)

The management of waste batteries is also controlled under the Waste Batteries and Accumulators Regulations (2009, as amended), which categorises batteries as automotive, industrial and portable and places controls on their treatment, recycling and export.

In addition to holding an appropriate environmental permit, if an operator wishes to treat or recycle waste automotive or industrial batteries or issue evidence on treated and recycled portable batteries they must be registered as an ABTO. Similarly, if an operator wishes to export waste batteries they will need to be registered as an ABE.

The requirements of the WBAR are separate to those of the Environmental Permitting Regulations and are not covered further in this guidance. Further guidance on the WBAR is available in:

• Waste batteries and accumulators: technical guidance
• Waste batteries treat recycle and export

1.4 Summary of common battery types, classification, chemistry and recycling

Common types of battery

A battery is a device that stores chemical energy and converts it to electrical energy. A battery may be made up of one or more cells, which have a positive and negative terminal or electrode (cathode and anode, respectively) and a conductive material known as the electrolyte. Plastic separators are typically used to keep the anode and cathode apart. The battery casing will be made from metal or plastic.

Primary batteries are not rechargeable, whilst secondary batteries are. For example, lithium-ion (Li-ion) batteries are secondary batteries, which are rechargeable and typically used in electric vehicles (EVs), battery energy storage systems (BESS), phones, computers and other electronic equipment. Lithium metal batteries currently available on the market are usually primary batteries, although secondary Li-metal batteries (for example, using Li metal anodes) are an area of future research and development.

The main types of waste battery that may be received at permitted waste facilities are likely to include:

Primary batteries:

• alkaline
• zinc-carbon
• lithium metal
• silver oxide
• mercury

Secondary batteries:

• nickel-cadmium (Ni-Cd)
• nickel-metal hydride (Ni-MH)
• lead acid
• Li-ion

Classification of waste batteries

In England, lead acid, Ni-Cd and mercury batteries are currently classified as hazardous wastes under the relevant List of Waste (LoW) codes. Unsorted collections of mixed batteries from households and businesses are also classified as hazardous wastes.

Separate collections of other batteries, including alkaline and lithium batteries, are currently classified under non-hazardous waste codes but are likely to contain substances or materials that have hazardous properties (for example, toxic or reactive metals and corrosive or flammable substances). Whilst within waste electrical equipment or end-of-life vehicles, lithium batteries (Li-ion and Li metal) are considered to be hazardous components. These batteries are also classified as dangerous goods for transportation under the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and the Carriage of Dangerous Goods Regulations (CDG).

Further information on the waste classification and coding of waste batteries can be found on Waste electrical and electronic equipment (WEEE): how to classify.

Battery chemistry

A typical alkaline battery consists of a manganese dioxide cathode, a zinc anode and a potassium hydroxide electrolyte. Zinc-carbon batteries are similar but typically use an ammonium chloride or zinc chloride electrolyte.

In a typical Ni-Cd battery, the cathode is made of nickel hydroxide and the anode is made of cadmium hydroxide, with a potassium hydroxide electrolyte.

In a typical Ni-MH battery, the cathode is made of nickel hydroxide (similar to a Ni-Cd battery), the anode (metal hydride) is made from a hydrogen-absorbing alloy (containing metals such as nickel, cobalt, manganese and aluminium, and rare earth elements such as lanthanum, cerium, neodymium and praseodymium) and an alkaline electrolyte, usually potassium hydroxide (similar to Ni-Cd and other alkaline batteries).

In lead-acid batteries, the electrolyte is a diluted sulphuric acid solution (usually less than 50% acid by weight). The electrodes are called plates; typically, these are conductive metal grids made from a lead alloy with lead-dioxide (lead dioxide paste) on the cathode and metallic lead (sponge lead) on the anode. Waste batteries are also likely to contain lead sulphate, resulting from the reaction between the electrodes and the battery acid.

There are two types of battery than contain lithium, Li-ion batteries and lithium metal batteries. Where the term ‘lithium battery’ is used in this guidance it is referring to both types.

Li-ion batteries pose a well-known and significant fire risk and are likely to contain other hazardous materials (for example, toxic metals). The cathode is aluminium foil coated with a lithium-metal oxide material (often referred to as the cathode active material (CAM)), for example, lithium-nickel-manganese-cobalt-oxide (NMC). There are various other Li-ion battery chemistries, which vary by the metals contained in the CAM, including lithium iron phosphate (LFP), lithium cobalt oxide (LCO), lithium manganese oxide (LMO) and lithium nickel cobalt aluminium oxide (NCA). The anode typically consists of copper foil coated with a graphite or carbon-based material. Most batteries currently available contain a liquid electrolyte consisting of a lithium hexafluorophosphate salt (LiPF6) dissolved in organic solvents. The electrolyte is likely to be hazardous and contain substances that are harmful, toxic, highly flammable and able to generate hydrofluoric acid when in contact with water. Advances in lithium-ion battery chemistry are typically focussed upon removing toxic metals (for example, Ni and Co) from the CAM and using a less hazardous electrolyte (including solid-state electrolytes).

Unlike Li-ion batteries, lithium metal batteries are usually non-rechargeable (primary batteries). The cathode of Li-metal batteries may be solid (for example, manganese oxide or iron disulphide) or liquid (for example, thionyl chloride). The anode is made from lithium metal foil. The lithium metal anode of the batteries can pose a significant fire risk due to the reactivity of lithium metal with water or moisture. The electrolyte is often a lithium salt dissolved in an organic solvent. Lithium thionyl chloride (LTC) batteries (commonly used in smart meters due to their long life) use a thionyl chloride electrolyte and cathode, which is toxic, corrosive and can react violently with water to produce harmful gases (for example, hydrogen chloride).

Sodium ion batteries (Na+-ion) are also being developed as a potential replacement or alternative to Li-ion batteries. These batteries are similar in function to Li-ion batteries and may pose similar risks depending upon their specific chemistry, for example, if they contain toxic metals in the CAM or a flammable electrolyte (for example, NaPF6 dissolved in organic solvents). Where this is the case, they should be managed in line with the measures provided in this guidance for Li-ion batteries.

Silver oxide batteries are small primary button batteries and contain a silver oxide cathode, zinc anode and an alkaline electrolyte (for example, sodium or potassium hydroxides).

Mercury batteries are similar to silver oxide and typically consist of a zinc anode, mercuric oxide cathode and a potassium hydroxide electrolyte. Selling battery button cells containing mercury was banned from 1 October 2015 by the EU Battery Directive (2006/66/EC).

Battery recycling

Once sorted into their different types or chemistries, batteries are usually recycled using mechanical treatment processes that break or shred the batteries and then sort and separate the mixed shredded material into different fractions, for example, metals (ferrous or non-ferrous), plastics, paper and electrolyte, which can be sent on for further recovery.

The treatment of batteries such as Li-ion and alkaline can produce a fraction known as black mass, which is subject to further treatment (either chemical or thermal) to recover the metals used in the electrodes (for example, lithium, nickel, cobalt, zinc). Lead plates and paste recovered from lead acid battery recycling processes are sent to lead smelters for refining and melting into ingots.

Because of the chemicals and materials contained in batteries, they need to be stored and handled safely (for example, to prevent damage, leakage, short-circuiting or over-heating) and the mechanical treatment (recycling) of waste batteries has the potential to result in the generation of:

• hazardous materials and residues, which will require safe handling and storage prior to their treatment or transfer
• emissions of polluting substances, which will require appropriate controls to make sure their environmental impact is prevented or minimised (for example, through appropriate containment and abatement)

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