Waste batteries: treat, recycle and export

Apply for approval as a facility to treat, recycle or export waste batteries for treatment and recycling and the rules you must follow.

You must follow extra rules if you manage waste batteries, including collection, treatment, recycling and export. These are in addition to your duty of care and hazardous waste regulation requirements.

The rules are different for waste portable, industrial and automotive batteries.

You must be an Approved Battery Treatment Operator (ABTO) if you:

  • treat and recycle waste portable batteries and want to issue evidence notes on them
  • treat and recycle waste industrial and automotive batteries

You must be an Approved Battery Exporter (ABE) if you:

  • export waste industrial or automotive batteries
  • export whole waste portable batteries and want to issue evidence on them
  • receive, and then export, waste portable batteries from an ABTO who has already issued evidence notes on them

Evidence notes are proof of treatment, recycling or export of portable waste batteries by an ABTO or ABE.

It’s illegal to send waste industrial or vehicle and other automotive batteries for incineration or to landfill.

Approved or appropriate person

You must be an approved or appropriate person to apply for approval and submit data returns.

See the guidance on what constitutes an approved or appropriate person.

Use the delegation of approved/appropriate person form if you want to delegate your function to another person. Sign the form and send it to your environmental regulator.

ABTO: apply for approval

To apply for approval you must have:

Apply for approval on the National Packaging Waste Database (NPWD).

You will need to fill in details about your business and submit a sampling plan and inspection plan.

Once approved you must comply with the conditions of approval.

ABE: apply for approval

To apply for approval you must have some form of UK presence; an office, a site or UK employees.

Apply for approval on the NPWD.

Once approved you must comply with the conditions of the approval.

Export and import laws

ABEs must follow the Waste Shipment Regulations.

Use the waste export control tool to find the regulatory controls for your battery waste’s destination country.

Follow the waste export and import guidance to move waste batteries or waste battery materials like lead plates in or out of the UK for treatment and recycling.

Equivalent standards

If you export to a site located outside of the European Economic Area, you must provide evidence that the site ensures their waste operations won’t endanger human health or harm the environment. You can provide:

  • copies of permits and licences to show that it’s a regulated site operating to equivalent UK standards
  • a statement from the competent authority under which the site operates, confirming that the site operates to equivalent UK standards

See the guidance on acceptable evidence of broadly equivalent standards.

How much it costs

The cost depends on the tonnage of waste batteries you deal with each year.

A small waste battery treatment operator or waste battery exporter is one that has, in the year the charge is payable, planned to:

  • issue no more than 15 tonnes of waste portable battery evidence notes
  • accept no more than 150 tonnes of waste automotive and industrial batteries
Item Annual application charge
Large battery treatment operator £2,570
Small battery treatment operator £500
Large battery exporter £2,570
Small battery exporter £500
Additional charge (small operator or exporter exceeds its planned tonnage) £2,070
Additional site to include in application £110 each

Battery collector

Make sure you know the difference between a battery collector and an ABTO or ABE.

A person or business that collects batteries and doesn’t sort or treat them need not be an ABTO or ABE but must follow the waste duty of care.

If you’re an ABTO or ABE and don’t have an arrangement in place with a battery compliance scheme (BCS) to treat or recycle batteries, you can only act for them as a battery collector. If you later make an agreement to act as an ABTO or ABE for the BCS, then you must accept the batteries as an ABTO/ABE and may issue evidence notes.

Comply with the conditions of your approval

There are rules on how you must store, sort and treat waste batteries.

Store waste batteries

You must store all waste batteries you accept as an ABTO or ABE in places with impermeable surfaces and suitable weatherproof coverings. Or the containers you use must have similar characteristics.

If you store batteries as a collector, your environmental permit will specify any storage conditions.

Sort waste batteries

Sorting batteries is classed as treatment. Sorting batteries is by type; portable, automotive and industrial and/or by chemistry: lead-acid, nickel-cadmium and ‘other’.

Treat waste batteries

Treatment includes sorting and preparing waste batteries for recycling or disposal.

Treatment does not include separating waste batteries from other waste, for example from WEEE or vehicles.

If, having separated batteries from other waste, you wish to then treat the waste automotive or industrial batteries by sorting into type and/or chemistry, you must be an ABTO.

Mixed loads

If you receive mixed loads of waste batteries, you must accurately record the proportion of automotive, industrial and portable batteries in the load, either by sorting each load or applying an agreed protocol. You must also assess and exclude the weight of any contamination in the load (for example a ‘lead’ ABTO accepts a load that includes ‘non-lead-acid’ batteries - they record the lead batteries by type and everything else as contamination).


The recycling process is complete when the waste material is classed as end of waste and becomes usable for its original purpose (for example, extracted metals from waste batteries used in manufacturing components for new batteries) or for other purposes (for example, for manufacturing other components).

Waste batteries used in energy recovery are not classed as recycling.


Your environmental regulator may accept a proposal from you for a site-specific protocol based on sampling data so that you don’t have to sort every load.

Until a protocol is agreed, the operator must sort all batteries. In the UK, sorting is a treatment activity, so any waste that includes industrial and/or automotive batteries can only be sorted by an ABTO.

A protocol lasts for a compliance year only and needs to be applied for annually in advance.

In your application explain:

  • why you need a protocol
  • the benefits to your business
  • what you will achieve by having a protocol

Support your case for a protocol with information on:

  • the weight of batteries you handle at your site, including by type and chemistry
  • the number and size of samples your propose to take; you will need more if you handle loads of varying content
  • details of your sampling methods, including how you work out battery weights, types, chemistry and contamination levels
  • how often you plan to repeat sampling to check the protocol is right for the battery loads you accept (for example, to confirm the specifications for the types and chemistries are broadly correct)
  • how your proposed samples are sufficiently representative of the battery loads you handle (for example, if 70% of loads come from one type of company, will you also take 70% of your sampling from them)
  • the documents or other evidence you use to check the battery types and source
  • whether the proportions of batteries in the loads seem reasonable
  • an explanation of any anomalies, like specific loads you receive and how you will handle them within the protocol

Your environmental regulator may ask for other information, or may wish to make a site visit before approving the protocol.

Keep records and report

You must record all the waste batteries you accept. Your records have two purposes; they provide:

  • proof that battery compliance schemes (BCS) have met their members’ (battery producers) obligation to treat and recycle waste portable batteries – known as evidence notes
  • environmental regulators information on waste batteries – known as waste data returns

It’s important you accurately classify, issue evidence notes and report on the batteries you accept. See technical guidance.

Issue evidence notes: portable batteries

You only issue evidence notes on portable batteries you accept for a BCS you’ve made an arrangement with. You can do this as soon as they arrive on site.

If you accept batteries and later make an arrangement with a BCS, you can issue evidence notes on these batteries as long as they’re still on your site.

If you make an arrangement after the end of a compliance year you can only issue evidence notes on the batteries once ‘accepted for a BCS’ the following year. For example, you accept batteries at your site in December 2012, then make a formal arrangement with a BCS in January 2013. The BCS will report the batteries as collected and delivered in Quarter 1 of 2013, and you will accept them as an ABTO/ABE in Quarter 1 and report them in this quarter. The evidence note will be for the 2013 compliance year.

To issue evidence notes on the NPWD you must enter your ABTO approval and facility number or ABE approval number. You record to the nearest kilogram the weight of batteries accepted for a BCS – you don’t need to break down the weight by battery chemistry.

You must:

  • only issue evidence notes on waste portable batteries if they can be recycled by the end of the following compliance period
  • ensure evidence is issued once, and once only, in the whole recycling and treatment chain – ABTOs or ABEs cannot issue evidence on waste portable batteries previously accepted and recorded by another ABTO

You must not issue evidence notes:

  • for more portable batteries than you receive in a compliance year
  • on any batteries an ABE receives that have previously been sorted or treated

Send reports

These are known as waste data returns. You must tell your environmental regulator the quantity and chemistry of each type of waste battery you accepted for treatment and recycling.

For waste portable batteries you must report quarterly on NPWD by the last day of April, July, October and January.

For waste industrial and automotive batteries you must report on NPWD once a year by 31 January in the year following the compliance period. You don’t need an arrangement with a BCS to accept these.


Failure to follow the regulations and carry out your duties may result in prosecution and a fine.

More information

See guidance on the rules for dealing with hazardous waste and the Environment Agency enforcement position statements:

  • Waste portable batteries delivered to battery collection points
  • Consignee returns: relaxation of reporting requirements for specified hazardous wastes

See the legislation and regulations for your responsibilities for waste batteries:

Published 26 June 2014
Last updated 29 July 2016 + show all updates
  1. Added text on equivalent standards when exporting waste batteries and a link to the acceptable evidence of broadly equivalent standards publication.

  2. Provided text on approved/appropriate person and a link to the delegation form to nominate someone else to fulfil this function.

  3. First published.