1 Executive Summary
This CIWM commissioned research project, ‘Batteries – the need for a new approach
towards Extended Producer Responsibility’, set out to review public attitudes towards
current producer responsibility arrangements for batteries and engage stakeholders to
inform and influence future management and recovery of used batteries. The work builds
on previous sector and issue engagement by CIWM including a 2020 webinar, and recent
work carried out by the Environmental Services Association (ESA).
Fires caused by batteries are a crisis for the resources and waste sector, for taxpayers,
for homeowners, and for Government. Addressing the problem is an emergency, and an
emergency response is required. Batteries are a perfect candidate for extended producer
responsibility and a deposit return scheme.
There were more than 1,200 fires caused by or suspected to have been caused bybatteries at UK waste and recycling sites and vehicles in 2023 (Material Focus, 2024), an
increase of 71% from 2022. These are batteries – in particular, high-powered,rechargeable batteries – that should not have been put in a bin, which should instead
have been taken to a collection point.
The cost of the damage and lost time from these unacceptable and entirely avoidable
fires caused by batteries is estimated at £158 million in annual damages (Eunomia,2021). Fortunately, so far no-one has been killed in any of these incidents however clearly
there is significant concern that this fortune may run out.
There are three reasons why these high-powered rechargeable batteries are ending up in
bins – the wrong waste in the wrong place:
1. Clear and impactful information on how to correctly dispose of used batteries is
not reaching consumers at point-of-sale or disposal and consumer awareness ofthe hazards is low due to a lack of funding for campaigns;
2. Batteries are finding their way into more and more everyday items, from singleuse vapes to toys and gadgets and even into clothes and shoes, and consumers
may be unaware an item even contains a battery;

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3. Producer responsibility rules have not kept up with changing chemistry andpervasiveness of technology, with little or no incentive for manufacturers or
retailers to change, placing the burden of cost onto local authorities.
Championing extended producer responsibility, and supporting the sector’s transition toa circular and net zero economy are key commitments for CIWM – along with promoting
safety for colleagues and consumer value for money.

1.1 What most consumers think about batteries
Our consumer research shows that the public are concerned over the impact and dangerof batteries, are keen to do the right thing and strongly support action for change.
There is a lack of knowledge, information and confidence amongst consumers on how todispose of batteries and gadgets that may contain batteries. This is particularly
problematic in relation to cheaper/lower value and smaller items, such as vapes andrechargeable toothbrushes, whereas higher-value items are more likely to be traded inor sold on, with fewer ending up in a bin.
Where batteries can be removed and replaced, i.e. traditional ‘AA’ batteries, they aremuch more likely to be taken back to a retailer or other collection point – by almost 70%
of people.
By contrast, higher value or larger items are more likely to be traded or otherwise taken
to a Household Waste & Recycling Centre (HWRC). Breaking this down for typicalexample items, the charts below show that the degree of confidence an individual may
have does not necessarily follow through into markedly improved outcomes, showing alack of information reaching consumers due to low point-of-sale and disposal cutthrough.
The public are ‘petrified’ when they discover the true impact of putting the wrong waste
in the wrong place, in this case a battery or an item containing a battery in the bin.

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1.2 There is strong support for a deposit-return scheme
Continuing with ‘business as usual’ is unacceptable and change must happen in orderthat this urgent crisis for our industry, for taxpayers and for Government can beaddressed.
Our research indicates that the public strongly support the use of deposits for items likebatteries. The level of deposit doesn’t need to be very high or set at a percentage of thevalue of a product, because the big-ticket items when it comes to ‘wrong waste – wrong
place’ are cheaper, smaller products such as vapes and toothbrushes.

1.3 There is a clear need for targeted action
The report shows that action on batteries should be targeted:
•
•

•
•

•

clear and unambiguous definitions for battery types and categories to prevent thecurrent lead-acid imbalance
problem products tend to be lower-value, smaller items e.g. rechargeable
toothbrushes, vapes etc, not higher value, expensive or large items, e.g.
smartphone, laptop, cordless garden tools
place a flat-rate deposit on batteries or products containing batteries, e.g. £2
potential for an eco-design ‘levy’ on products where currently batteries cannot be
removed or replaced, as an incentive to producers to improve design and/or toconsumers to buy a different product in lieu of inaction by manufacturers
unclaimed deposits/levy income should be used to promote research anddevelopment – these should be cost-neutral as the objective must be to set up
systems for success… EPR should be there to cover collection/recycling costs.

By encouraging removable batteries and supporting the right to repair, products will bebetter made e.g. motors will have to last several battery-life cycles and/or be repairable
too, ensuring products last longer and offer consumers better value-for-money.
CIWM supports the expansion of take-back schemes which are the right approach tosupport the mission of ‘simpler recycling’:••

making the problem and solution visible to consumers;
ensuring the producer pays; andPage 3 of 76
Batteries – the need for a new approach towards Extended Producer Responsibility•enabling the management of deposit scheme administration and levy collection(collected for and on behalf of the exchequer at point of sale, akin to VAT).

Whilst this will interrupt ‘Business as Usual’ and be mildly inconvenient for retailers andmanufacturers, it’s much less inconvenient than setting fire to vehicles and facilities
used to manage society’s waste and recycling.

1.4 We need a new deal for consumers
1. Battery manufacturers and retailers need to act immediately and work with the CIWM
to promote safer, simpler recycling, ensure ‘the right waste in the right place’ andcelebrate success, such as measures being put in place by the Bicycle Association tocollect e-bike batteries, which make the problem and solutions more visible.
It is great to see voluntary schemes being implemented which take the issue ofbatteries, battery disposal and battery safety seriously and it is exactly these sorts ofschemes that should become mandatory under EPR.
2. Chemistry-specific targets must be brought in and introduced as part of the process
of updating existing battery producer responsibility legislation to an EPR for batteries,
as a matter of urgency to ensure consumers can access collection points andindustry-funded take-back schemes for high-powered rechargeable batteries anditems containing these batteries – lead acid batteries account for 70% of recycling
evidence but are just 3% of the UK market.
Currently compliance is a box-ticking exercise – targets are being easily met at theexpense of disincentivising investment in capacity to handle and recycle non-leadacid batteries. This is a quirk of the current out-of-date regulations and needs
reviewing urgently, however this amendment to the current regulations is only a quick
fix to address the current emergency situation being caused by batteries; it is not along-term solution.
3. Work should start immediately on a deposit-return scheme for batteries which our
research shows the public strongly supports this measure and the problem items are
generally smaller/cheaper where a modest deposit will have the highest impact.

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We think a modest, flat rate deposit on all batteries or items containing batteries
would be simple and effective, targeting the most problematic products and spurring
action to address the issues flagged above. Retailers and manufacturers would needto ensure battery collections or collection points were available.
Deposits would have the additional effect of challenging manufacturers to come up
with better product designs, drive more products to have removeable and replaceable
batteries and bring about the beginning of the end of designed-in obsolescencedictated by battery life. This would vastly improve safety of products at the end-of-life,
reducing the risk to CIWM members and the public, and improve value for money
through repairability.
4. Support needs to galvanise around the development of domestic rare-earth material
circularity and tech circularity businesses – this is not about amending end-of-life
regulations, but a fundamental shift in attitudes from ‘cost’ to ‘value’ through right-torepair and eco-design principles.
With global demand for rare earths materials expected to reach 466,000te by 2035, up
from 170,000te in 2022, clearly there is demand for these materials. Urgent
Government action is needed to support R&D investment in rare-earth material
recycling.
Combined with the above points, the UK should lead by example and move from being
one of the most wasteful societies in the world when it comes to electrical andelectronic equipment, to become one of the most progressive and resourceful,respecting the safety of others and grasping the opportunity presented by mining theurban environment for valuable materials, supporting manufacturing and export,
creating jobs and skills as a result.
CIWM is taking a lead on the issues end-of-life batteries are having on workers within the
Resource & Waste sector, and the lost opportunity that this currently presents as an
example of why EPR needs to be extended. CIWM is:•••standing up for consumers;
protecting workers in the resources and waste sector;
safeguarding critical raw material and driving the UK towards a more circular
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Ultimately, we see a clear path towards ‘EPR of Everything’ as a policy priority area,
focusing on materials, products and sectors where either there is no current or direct
producer responsibility code or requirement, or where what does exist has demonstrably
fallen short in delivery or fallen behind current technology, policy or practice as is thecase with batteries.

1.5 Conclusions
The impacts of selling cheap, single-use plastic items containing a non-rechargeable,
single-use battery were entirely foreseeable. The same is true of embedding powerful,rechargeable batteries inside electrical and electronic products – making themremoveable and replaceable is the minimum requirement.
The experience with disposable vapes demonstrates that the problems were entirely
foreseeable but that we will have had to wait around a decade, facing a growing problem,
before legislation finally catches up.
It cannot be allowed to happen with clothing and aftermarket bike parts, both of which
increasingly appear in general waste containing high-powered, rechargeable batteries.
Unless we change things, the main impact will, of course, be on local authorities, charity
shops and recycling collection companies, not on retailers and manufacturers.
We must ensure we use our foresight to never make the same mistakes again.

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2 Table of Contents
1

Executive Summary .......................................................................................................... 1
1.1

What most consumers think about batteries ............................................................... 2

1.2

There is strong support for a deposit-return scheme .................................................... 3

1.3

There is a clear need for targeted action ...................................................................... 3

1.4

We need a new deal for consumers ............................................................................. 4

1.5

Conclusions ............................................................................................................... 6

3

Acknowledgements.......................................................................................................... 94

Overview........................................................................................................................ 10

5

4.1

History, challenges, problems, policies and situation report ...................................... 10

4.2

Recent history of battery technology development .................................................... 10

4.3

History of producer responsibility ............................................................................. 13

4.4

Challenges and problems ......................................................................................... 15

4.4.1

Recycling of Batteries ....................................................................................... 18

4.4.2

Critical raw materials ........................................................................................ 20

4.4.3

Lithium ............................................................................................................. 22

4.4.4

Hazards – why do rechargeable batteries catch fire? .......................................... 24

4.5

Situation report – an increasing number of incidents in the UK ................................... 26

4.6

Policies .................................................................................................................... 27

4.7

Awareness ............................................................................................................... 28

4.8

Repairability ............................................................................................................. 29

4.9

The ‘Right-to-repair’.................................................................................................. 30

4.9.1

Europe ............................................................................................................. 31

4.9.2

California ......................................................................................................... 32

4.9.3

United Kingdom ................................................................................................ 32

4.10

Vapes, scooters, e-bikes, cars and Parliament ...................................................... 33

4.11

Taking responsibility – bikes .................................................................................. 35

4.12

Clothes ................................................................................................................ 35

4.13

Hope – cars .......................................................................................................... 37

Attitudes and awareness: survey sector and public attitudes ........................................... 38
5.1

The Narrative ............................................................................................................ 38

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5.2

Methodology ............................................................................................................ 38

5.3

Results of engagement with CIWM members and sector stakeholders (Phase 1) ........ 40

5.3.1

Questions 5 & 6 – awareness of correct disposal................................................ 40

5.3.2

Question 9 - biggest barriers.............................................................................. 41

5.3.3
Question 10 – the most important things to fix with respect to addressing thehazards presented by incorrect battery disposal ............................................................. 42
5.3.4
Question 11 - do you think a deposit return scheme for batteries could provide asolution? ....................................................................................................................... 43
5.3.5

Question 13 – vapes, what action should be taken ............................................. 45

5.4 Results of consumer research on existing consumer behaviours, motivations andbarriers (Phase 2) .............................................................................................................. 46

6

5.4.1

Levels of ownership .......................................................................................... 46

5.4.2

Disposal ........................................................................................................... 46

5.4.3

Awareness of problems .................................................................................... 51

5.4.4

Recall of, and reaction to, the ‘Take Charge’ campaign ...................................... 54

5.4.5

A DRS for batteries ............................................................................................ 58

5.4.6

Vapes / e-cigarettes .......................................................................................... 60

Conclusions .................................................................................................................. 62
6.1

So why an ‘EPR of everything’? .................................................................................. 62

6.2

So let’s talk about deposits ....................................................................................... 64

6.3

Cost versus Value – changing the narrative ................................................................ 64

6.4

So why start with batteries? ...................................................................................... 65

6.5

We need a new deal for consumers ........................................................................... 67

6.6

CIWM’s “New Deal for Consumers” in detail ............................................................. 69

6.7

CIWM’s support for developing circular economy opportunities ................................. 71

6.8

Vapes – a salutary lesson .......................................................................................... 72

6.9

Closing comments ................................................................................................... 73

Appendix A .......................................................................................................................... 74

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3 Acknowledgements
This report was commissioned by the Chartered Institution of Wastes Management(CIWM) and written by John Twitchen, from the consulting company env23.
John is an environmental sciences graduate, a Fellow of the Chartered Institution ofWastes Management and Chair of the Institution’s Producer Responsibility StrategicExpert Group.
He has worked in the resources and waste industry for over thirty years. John set up the
UK's first specialist environmental communications consultancy, Sauce, and has since
established the Earthshot Prize nominated and award-winning circular economy
company, Stuff4Life.

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4 Overview

4.1 History, challenges, problems, policies andsituation report
For more than a decade, ‘batteries’ have been subject to producer responsibility
requirements in the UK; the system relies on consumers (households and businesses) tosegregate batteries from other waste items and either take them to a drop-off point or
arrange for a collection.
Organisations over a certain size may be subject to producer responsibility
requirements, in most cases requiring them simply to provide a collection point e.g. forconsumers (householders or small businesses). Some local authorities provide
householders with kerbside collections and most offer drop-off points at Household
Waste Recycling Centres.

4.2 Recent history of battery technology development
Over the last twenty years, consumer batteries have undergone significant evolution interms of technology, performance, and applications. The key developments can besummarised as follows:➢ Lithium-ion Dominance: Lithium-ion (Li-ion) batteries have become the dominant
technology for consumer electronics. They offered higher energy density, longer
cycle life, and lighter weight compared to traditional nickel-based batteries,
enabling batteries to be smaller relative to energy output.
➢ Increased Energy Density: Continuous research and development efforts led to
improvements in the energy density of batteries. This allowed for more compact
and lightweight devices with longer-lasting battery life.
➢ Advancements in Lithium Polymer Batteries: Lithium polymer (Li-poly) batteries
emerged as a variation of Li-ion batteries, offering flexibility in form factor. This
made them suitable for slim and curved devices, such as smartphones andwearables.

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Batteries – the need for a new approach towards Extended Producer Responsibility➢ Fast Charging Technologies: The demand for faster charging times led to thedevelopment of various fast charging technologies, such as Qualcomm's Quick
Charge, USB Power Delivery, and proprietary solutions from smartphone
manufacturers. These technologies significantly reduced the time required tocharge devices.
➢ Energy-Efficient Devices: Manufacturers focused on optimizing the energy
efficiency of electronic devices, leading to better overall battery life. This involved
improvements in both hardware and software to minimize power consumption
during various usage scenarios.
➢ Introduction of Solid-State Batteries: In recent years, there has been growinginterest in solid-state batteries as a potential successor to traditional Li-ion
batteries. Solid-state batteries promise higher energy density, improved safety,
and longer lifespan; commercialisation is in progress.
➢ Electric Vehicles (EVs) Revolution: The automotive industry witnessed a shift
towards electric vehicles, driving advancements in battery technology. Highcapacity Li-ion batteries became crucial for extending the range of electric cars,and ongoing research aims to improve their performance and reduce costs.
➢ Environmental Considerations: With increasing awareness of environmental
issues, there has been a focus on developing more sustainable battery
technologies. Efforts include recycling programs and the exploration ofalternative materials to reduce the environmental impact of battery production
and disposal.
➢ Integration of Smart Battery Management: Smart battery management systems
became integral for optimising battery performance, preventing overcharging,and enhancing overall safety. These systems are crucial in ensuring the longevity
and reliability of batteries in various devices.
➢ Wireless Charging Standardisation: The standardisation of wireless charging
technologies, such as Qi wireless charging, became more widespread. This
allows for greater convenience and eliminates the need for physical connectors
in some devices.

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Overall, the evolution of consumer batteries over the last two decades has been marked
by advancements in energy density, charging technologies, environmental
consciousness, and the exploration of new battery chemistries to meet the growing
demands of modern electronics and electric transportation.
This in turn has led to a proliferation of use and liberal regulations have led to unintended
consequences the resource management sector now faces daily in the form of dangers
to people and property posed by explosions and fires caused by batteries that have been
disposed of incorrectly.

Figure 1: Aftermath of a huge fire at Carmarthen recycling
facility in 2021, where a battery was found to be the cause

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Figure 2: Aftermath of a domestic fire caused by a rechargeable
battery (from London Fire Brigade)4.3 History of producer responsibility
Battery producer responsibility regulations have been implemented in various regions
globally to address the environmental impact of batteries and promote their responsible
disposal and recycling. The history of these regulations can vary by country and region,
but here is a general overview:➢ 1990s - Early Awareness: In the 1990s, concerns about the environmental impactof batteries, particularly those containing heavy metals like cadmium andmercury, started to gain attention. These concerns were linked to the improper
disposal of batteries, which led to soil and water contamination.
➢ EU Battery Directive (2006): In the European Union (EU), the Battery Directive wasadopted in 2006. The directive aimed to minimise the environmental impact ofbatteries and accumulators, especially those containing hazardous substances.
It introduced requirements for labelling, collection, recycling, and proper
disposal of batteries.
➢ Global Momentum: Following the EU's lead, other countries and regions began toimplement or explore battery producer responsibility regulations. The focus wasPage 13 of 76
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on minimising the environmental impact, increasing recycling rates, and reducing
the presence of hazardous materials in batteries.
➢ Revisions and Amendments: Over the years, the EU Battery Directive has
undergone revisions to adapt to technological advancements and changing
environmental priorities. Amendments have been made to include new battery
technologies, such as lithium-ion batteries commonly used in consumer
electronics and electric vehicles.
➢ National Legislation: Many countries around the world have implemented theirown battery producer responsibility regulations. These regulations often require
manufacturers to take responsibility for the entire lifecycle of their batteries, fromproduction to proper disposal and recycling.
➢ Extended Producer Responsibility (EPR): The concept of Extended Producer
Responsibility has become a guiding principle in many regulatory frameworks.
Under EPR, producers are responsible for managing the environmental impact of
their products throughout their life cycle. This includes financing and organisingcollection, recycling, and disposal systems.
➢ Incentives for Recycling: Some regions have introduced incentives for battery
recycling, encouraging manufacturers to design products with recycling in mind
and supporting the development of efficient recycling infrastructure.
➢ Technology-Specific Regulations: As battery technologies evolve, regulations
may need to be adapted to address the unique challenges posed by different
types of batteries, such as lithium-ion batteries used in electric vehicles andportable electronics.
➢ Global Harmonisation Efforts: Recognising the global nature of the electronics
industry, there have been efforts to harmonise regulations to some extent,
facilitating international trade while ensuring responsible management ofbatteries.
The specifics of battery producer responsibility regulations vary widely between
countries and regions. The regulatory landscape continues to evolve as newtechnologies emerge, and environmental priorities shift. However, in the UK and indeed
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across Europe, regulations have fallen behind chemistry and technology, as well as how
batteries are used (e.g. being embedded in products and used in a wider range ofconsumer products).

Did you know…?
Nike produced the first pair of trainers toinclude a rechargeable battery in a redesign ofMarty McFly’s 1989 Nike MAGs in ‘Back to the
Future’ (set in futuristic 2015). 1,500 pairs
were auctioned online in 2011 with proceeds
going to the Michael J. Fox Foundation.
The battery was apparently good for 3,000
hours of operation.

Figure 3: image of Nike MAG(from Wikipedia)

4.4 Challenges and problems
The main challenges presented by batteries are quite straightforward:
•
•
•

•

•

the producer responsibility requirements are out of date and haven’t kept up withmarket activity, being chemistry agnostic
producer responsibility targets are being met by collecting heavier, less volatile
batteries
high-powered, rechargeable batteries are now prevalent and often embedded in
items (including cheap consumer goods such as bike lights, even clothing; and insingle-use items e.g. vapes)
when crushed or damaged, high-powered, rechargeable batteries can combust
and cause fires, damaging vehicles and buildings used to transport, store orprocess waste and endangering lives
despite a requirement to ‘raise awareness’ efforts have been mediocre due to alack of urgency by producers who are meeting targets without the need to collecthigh-powered batteries that are the main cause of problems.

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The key issue is the ‘anomaly’ or ‘vast misreporting’ of lead acid batteries in the UK,comments which were reported in an MRW article ‘published 17 November 2023, by aspokesperson for the Approved Authorised Treatment Facility (AATF) Forum. The AATF’s
figures suggest that ten times more portable lead acid batteries were collected forrecycling than the number that were sold, as per Table 1 below. This is widely seen as the
key blocker of investment in treatment and recycling facilities for other battery
chemistries, as targets are currently chemistry agnostic.

Table 1: AATF figures

While consumer electronics have benefited greatly from advancements in battery
technology, there are still several challenges and problems associated with batteries inthese devices, with common issues including:
1. Limited energy density: Despite improvements, the energy density of batteries
remains a challenge. Consumers often desire longer battery life, but achieving
this without increasing the size and weight of the battery can be difficult.
2. Slow charging times: Although there have been strides in fast charging
technologies, many consumers still find charging times to be relatively slow. Thisis especially true for larger devices like laptops and electric vehicles.

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3. Limited lifespan: Batteries have a finite lifespan, typically measured in charge
cycles. Over time, a battery's capacity diminishes, leading to shorter battery life.
This degradation is a concern for consumers who want their devices to remainfunctional for an extended period.
4. Safety concerns: Safety issues, such as overheating and the rare occurrence ofbattery fires, can pose serious risks. These concerns are particularly significant incases of poorly manufactured or damaged batteries.

Figure 4 - Battery exploding in a recycling facility endangering employees(picture from ESA Zombie Batteries campaign/ITV News)

5. Environmental impact: The production, use, and disposal of batteries contributeto environmental challenges. Mining for raw materials, manufacturing processes,
and the disposal of used batteries raise environmental concerns. Efforts are being
made to develop more sustainable and recyclable battery technologies.
6. Costs and affordability: Advanced battery technologies, such as lithium-ion, canbe expensive to manufacture. This cost is often passed on to consumers,
affecting the overall affordability of electronic devices, especially those withlarger and more powerful batteries.

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7. Size and weight constraints: As devices become smaller and more portable,
there is a constant demand for smaller and lighter batteries. Balancing the needfor compactness with the desire for increased energy storage capacity remains achallenge.
8. Dependency on rare materials: Many advanced batteries rely on materials thatare scarce or sourced from specific regions. This dependence on rare materials
can lead to supply chain issues and price volatility.
9. Incompatibility of charging standards: The lack of a universal charging standard
for all devices can be inconvenient for consumers. Different devices may requiredifferent charging cables and adapters, leading to clutter and frustration.
10. Memory effect: While less common in modern lithium-ion batteries, certain older
battery chemistries were prone to the memory effect, where the battery"remembered" its capacity and would not charge fully if not completely
discharged first.
Addressing these challenges requires ongoing research and innovation in battery
technology, as well as the development of sustainable practices throughout the entire
lifecycle of batteries, from production to disposal.

4.4.1 Recycling of Batteries
The recycling of traditional batteries (e.g. lead-acid based chemistry) is well established.
According to figures published on the Environment Agency’s National Packaging Waste
Database (NPWD), in 2023 45.5% of portable batteries placed on the market in the UK
were reported as being recycled, just exceeding the target of 45%. However, despite this,
it is estimated that approximately 20,000 tonnes of batteries end up in landfill every year
(or end up incinerated), apparently enough energy to power a city the size of Birmingham
for an entire day.
In the UK there are five registered battery compliance schemes (scheme names followedby scheme operators in brackets): BatteryBack (Wastecare Compliance Plc); Ecosurety
Batteries Ltd (Valpak Batteries Limited) ; ERP UK Ltd (ERP UK Ltd) ; REPIC (RESC Limited);and Valpak Ltd (Valpak Ltd), and a number of recognised, registered battery recycling
companies, focused primarily on traditional batteries and driven through compliance
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with existing batteries regulations. The following organisations offer battery collection
and recycling in the UK, and access to overseas reprocessing:Enva - waste management and recycling company that operates in the UK. They offer
battery recycling services, among other waste management solutions.
Ecosurety - recycling compliance scheme in the UK that works with businesses toensure proper waste management, including battery recycling.
Veolia - global environmental services company with a presence in the UK. They offer
recycling services, including the recycling of batteries and other electronic waste.
Cawleys Waste Management - waste management company in the UK that provides
recycling solutions, including the recycling of batteries and electronic waste.
Electrocycling - specialise in the recycling of electronic waste, including batteries. They
operate in compliance with environmental regulations and provide recycling services in
the UK.
Gem Recycling - waste management company in the UK that offers recycling services,
including the recycling of batteries.
Recolight - primarily focuses on the recycling of lighting equipment but also participate
in the recycling of batteries, including those used in electronic devices.
However, recycling lithium-ion style rechargeable batteries is more challenging andtechnology is still emerging. In the UK as in many other jurisdictions, this is hampered bya lack of meaningful targets in place for all battery chemistries. Despite this, there are anumber of emerging recycling technology companies and a growing industry aroundrarer materials:
G&P Batteries - UK-based company that specialises in battery recycling services. They
handle a variety of battery types, including lithium-ion batteries.
Technology Minerals - set to open the “UK’s first” industrial-scale lithium-ion (Li-ion)battery recycling facility. The company has announced that its 48.25% owned battery
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Environment Agency (EA) to commence full operations at its lithium-ion (Li-ion) battery
recycling plant in Wolverhampton.
Umicore - global materials technology and recycling company. They are known for theirexpertise in recycling various materials, including precious metals and battery materials.
Umicore has a strong focus on sustainable practices and plays a significant role in therecycling of lithium-ion batteries.
Retriev Technologies - specialises in the recycling of lithium-ion batteries for various
applications, including those used in electric vehicles (EVs) and consumer electronics.
They offer solutions for both battery manufacturers and end-of-life battery disposal.
Battery Solutions - provides battery recycling services, including the recycling oflithium-ion batteries. They work with a variety of industries, including electronics
manufacturers, to responsibly handle battery waste.
Li-Cycle – focuses on advanced lithium-ion battery recycling technologies. They use aproprietary process to recover high-purity materials from batteries, aiming to create aclosed-loop system for battery materials.
American Manganese – focuses on the recycling of lithium-ion batteries, with aparticular emphasis on recovering valuable metals like cobalt, lithium, nickel, andmanganese using their patented recycling process.

4.4.2 Critical raw materials
Critical raw materials (CRMs) are natural resources including lithium that are crucial forthe development and manufacturing of advanced technologies, high-tech products, andstrategic industries. These materials are essential for economic growth, innovation, andthe transition to a more sustainable and technologically advanced society. However, theavailability and sustainable sourcing of critical raw materials pose significant
challenges, including:
1. Geopolitical dependence: Many critical raw materials are concentrated in a few
countries or regions, leading to geopolitical dependence. This dependence canpose risks related to supply disruptions, trade tensions, and the potential use ofresource-related strategies as geopolitical leverage.
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2. Supply chain vulnerability: The global supply chains for critical raw materials arecomplex and interconnected. Disruptions caused by geopolitical events, natural
disasters, economic shifts, or global crises (such as the COVID-19 pandemic) can
impact the availability and pricing of these materials.
3. Market concentration: The extraction and processing of some critical raw
materials are dominated by a small number of companies or countries. This
market concentration can lead to limited competition, pricing volatility, andpotential supply issues.
4. Environmental and social impacts: The extraction and processing of critical raw
materials often have environmental and social implications. Unsustainable
mining practices, habitat destruction, water pollution, and social conflicts canarise, leading to negative environmental and human rights consequences.
5. Resource depletion: Some critical raw materials are non-renewable resources,
and their extraction can lead to resource depletion. Overexploitation of theseresources without effective recycling and substitution strategies can result in
long-term supply challenges.
6. Lack of diversification: Overreliance on a specific material for a particularapplication can create vulnerabilities. Diversification in material use andexploration of alternative materials with similar properties can help mitigate risks
associated with the scarcity of a single critical raw material.
7. Technological advances and changing demand: Rapid technologicaladvancements and shifts in market demand can alter the landscape of criticalraw material usage. New technologies may emerge, reducing reliance on certain
materials or creating increased demand for others.
8. Recycling challenges: Efficient recycling processes for many critical raw
materials are often lacking or economically challenging. Developing effective
recycling technologies and establishing robust recycling infrastructure is crucial
for mitigating the reliance on primary raw material extraction.

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9. Trade and export restrictions: Some countries impose export restrictions on
critical raw materials to ensure domestic supply or protect resources. These
restrictions can disrupt global supply chains and create challenges for industries
reliant on these materials.
10. Policy and regulatory hurdles: The absence of clear and consistent policies orregulations related to critical raw materials can impede sustainable sourcing andsupply chain management. Regulatory frameworks that promote responsible
sourcing, recycling, and substitution are essential.
Addressing these challenges requires international collaboration, sustainable resource
management practices, investment in research and development, and theimplementation of policies that balance economic interests with environmental andsocial considerations.
The European Union and other regions have taken steps to address critical raw material
challenges through initiatives focused on responsible sourcing, recycling, and reducing
dependency on specific materials.

4.4.3 Lithium
The lithium supply chain faces several challenges that can impact the availability andcost of lithium, a critical raw material used in batteries for EVs, renewable energy
storage, and various electronic devices. Some of the key challenges with lithium supply
include:1. Geopolitical concentration: A significant portion of the world's lithium reserves
is concentrated in a few countries, with the "lithium triangle" in South America(Chile, Argentina, and Bolivia) containing a substantial share. Geopoliticalfactors, including political instability and policy changes in these regions, canaffect the global supply of lithium.
2. Extraction and production costs: Lithium extraction and processing can beenergy-intensive and costly. The cost of lithium production, including mining,brine extraction, and chemical processing, can influence the overall cost oflithium-ion batteries.

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3. Limited number of producers: The lithium market is characterized by a limited
number of major producers. This lack of diversity in the supply chain can lead toconcentration risks, including potential supply disruptions due to issues faced bya small number of producers.
4. Resource depletion: As demand for lithium continues to rise with the growth ofelectric vehicles and renewable energy storage, concerns about resource
depletion have emerged. Sustainable and responsible mining practices are
essential to address these concerns.
5. New discoveries and exploration: Ongoing exploration efforts are needed to
discover new lithium deposits and expand the available reserves. Geologicalchallenges, exploration costs, and environmental considerations can impact thepace at which new lithium resources are identified and developed.
6. Environmental and social concerns: The extraction of lithium, particularly frombrine deposits, can have environmental and social impacts. Issues such as water
usage, habitat disruption, and potential conflicts with local communities canarise and must be addressed for responsible and sustainable lithium production.
7. Technology shifts and substitution: The rapid evolution of battery technology
may lead to the development of alternative chemistries that do not rely on lithium.
While this could reduce dependence on lithium, it may introduce new challenges
associated with the production and availability of alternative materials.
8. Transportation and infrastructure challenges: The transportation of lithiumfrom production sites to manufacturing facilities and end-users can facelogistical challenges, including issues related to infrastructure, transportation
costs, and potential bottlenecks in the supply chain.
9. Trade and export policies: Export restrictions imposed by lithium-producing
countries can impact the global supply chain. Changes in trade policies or export
quotas can affect the availability and pricing of lithium on the international
market.
10. Investment and financing: The expansion of lithium production capacity
requires significant investment. Financing challenges or uncertainties about
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Batteries – the need for a new approach towards Extended Producer Responsibilitymarket demand can affect the willingness of companies to invest in new lithium
projects.
Addressing these challenges involves a combination of technological innovation,
sustainable mining practices, international collaboration, and investment in explorationand production.
Efforts to improve recycling technologies and promote circular economy principles cancontribute to a more sustainable and resilient lithium supply chain.
However, given the aforementioned shortage of capacity in the UK and Europe, there
remains both a challenge and an opportunity here in the UK to ensure critical raw
materials such as lithium can be recovered, retained and utilised in what presents amajor opportunity for investment in the UK economy.

4.4.4 Hazards – why do rechargeable batteries catch fire?
Rechargeable batteries, particularly lithium-ion batteries, have been known to catch fireor experience thermal runaway events. Several factors contribute to the risk of fire or
thermal incidents in rechargeable batteries:
1. Chemical composition: Lithium-ion batteries contain flammable electrolytes,
typically in the form of a lithium salt dissolved in a solvent. The combination ofhighly reactive lithium and flammable electrolytes can lead to thermal runaway if
the battery is damaged or subjected to conditions that cause internal shortcircuits.
2. Physical Damage: Physical damage to the battery, such as puncture, crushing,or impact, can compromise the integrity of the battery's internal components.
This damage can lead to the formation of internal short circuits, triggering rapid
and uncontrolled chemical reactions within the battery. Damage could be due toan accident or, of course, from being crushed if a battery or a gadget containing abattery is incorrectly disposed of in a waste or recycling bin, and crushed duringcollection, transportation, sorting or landfilling.
3. Overcharging: Overcharging a rechargeable battery can cause the formation oflithium metal on the battery's anode, leading to internal short circuits and thermal
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Batteries – the need for a new approach towards Extended Producer Responsibilityrunaway. Overcharging can be a result of faulty charging circuits or the use ofincompatible chargers.
4. Over discharging: Discharging a battery below its recommended voltage range
can cause the formation of metallic lithium on the battery's anode. This can resultin the growth of dendrites, which are conductive filaments that can pierce theseparator between the battery's electrodes, leading to internal short circuits.
5. Manufacturing defects: Poor manufacturing practices or defects in the
production of rechargeable batteries can introduce weaknesses in the battery's
structure, making it more susceptible to thermal events.
6. External factors: Exposure to high temperatures, excessive humidity, or otheradverse environmental conditions can contribute to the degradation of thebattery's internal components and increase the risk of thermal runaway.
7. Incompatible chargers: Using chargers that are not designed for a specific typeof rechargeable battery or using counterfeit chargers can lead to overcharging,overheating, and other safety hazards.
8. Poor quality control: In some cases, rechargeable batteries may be producedwith inadequate quality control measures, leading to variations in the
manufacturing process that can impact the safety and performance of thebatteries.
9. Design flaws: Some battery designs may have inherent flaws that increase therisk of thermal runaway. This could include issues related to the separation
between the battery's electrodes, the choice of materials, or the design of thebattery management system.
Manufacturers implement safety features and incorporate battery management systems
to minimize the risk of fire or thermal events in rechargeable batteries. These safety
features include thermal protection, overcharge protection, and short-circuit protection.
However, users must also follow proper charging practices, avoid physical damage tobatteries, and use quality chargers to ensure the safe operation of rechargeable
batteries.
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4.5 Situation report – an increasing number of incidents
in the UK
As previously mentioned, each year in the UK alone, approximately 20,000 tonnes ofbatteries end up in landfill. It is clear that producer responsibility requirements need to
be updated – too many fires have already been caused and too many lives endangered,post-collection. The government estimates that five million disposable vapes are thrownaway each week, up from 1.3 million from last year. “Over a year, this is equivalent to thelithium batteries of 5,000 electric vehicles.”Eunomia Research and Consulting found that lithium-ion batteries currently cause
about 48% of all waste fires in the UK each year, resulting in £158 million in annual
damages.
We could cite 20, 50, 100 recent examples of fires caused by batteries at waste
management facilities… here is one of the most recent, featuring an aftermarket e-bikeconversion very close to home in Bournemouth.
The problem is very serious – poor quality rechargeable batteries included in or added toeveryday items such as bikes, scooters etc left in hallways to charge overnight, havecaused fires and lives have been lost. Whilst these ‘upstream’ issues are out-of-scope
for this report, it is nevertheless important to consider how end-of-life and circularity
solutions could help to address issues of quality and consumer awareness, increasing
people’s knowledge of hazards and reducing risks.
The Government is now taking action to address certain battery issues, with a call forevidence due to be launched early next year focused on increasing collection andrecycling rates for batteries. The primary focus is to support the UK's transition to electricvehicles (EVs), and follows publication of its Battery Strategy.
Concerns over the number and size of EV car batteries that will require end-of-life
management in the coming years and decades is the equivalent of focusing on saving
rhinos and tigers - the ‘charismatic megafauna’ effect whereby the severe massextinction event continues with the loss of hundreds of other species through thediversion of funds into big game parks.

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All the while people are trying to solve how to recycle large EV batteries ‘in the future’,
there are compact and powerful lithium-ion batteries in smaller, cheaper electrical items
causing damage, destruction and deaths every day.

4.6 Policies
Several regulations in the United Kingdom govern the production, sale, and disposal ofbatteries:
1. The Waste Batteries and Accumulators Regulations 2009 (as amended): Thislegislation implements the EU Battery Directive in the UK and sets out
requirements for the collection, treatment, recycling, and disposal of waste
batteries and accumulators. It also includes obligations for producers,
distributors, and end-users. After extensive industry engagement, the regulations
focused on end-of-pipe collection rather than a wider view on design,
manufacture, use and chemistry.
2. The Waste Electrical and Electronic Equipment (WEEE) Regulations: In the UK
these regulations primarily focus on waste management, recycling, and theproper disposal of electrical and electronic products, including batteries. The
regulations aim to reduce the environmental impact of electronic waste byencouraging recycling and responsible disposal.
3. Extended Producer Responsibility (EPR) Regulations: The UK government has
been considering and implementing extended producer responsibility schemes,
which are part of a broader strategy to shift the financial and operational burdenof waste management from local authorities to producers. The aim is toencourage producers to design products with end-of-life considerations in mind
and to fund the collection and recycling of their products.
4. UK REACH Regulations: The UK's REACH (Registration, Evaluation,
Authorization, and Restriction of Chemicals) regulations, which came into effectafter the end of the Brexit transition period, regulate the use of certain chemicals
in products, including batteries. Compliance with REACH may involve registration
and reporting requirements for substances used in batteries.

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5. Ecological design requirements: The UK may adopt ecological design
requirements for batteries, aligning with EU regulations. These requirements
focus on improving the environmental performance of batteries by setting criteria
related to their energy efficiency, recyclability, and other factors.
6. Product safety and standards regulations: Batteries sold in the UK must comply
with safety and standards regulations. These regulations ensure that products,
including batteries, meet specified safety requirements to protect consumers.
7. Batteries (Placing on the Market) Regulations 2010 (as amended): This set of
regulations outlines rules regarding the placing on the market of batteries andaccumulators, including labelling requirements and restrictions on the presenceof certain hazardous substances.
Additionally, Europe has recently consulted on new rules concerning removeable andreplaceable batteries, supported by European waste and recycling representative
groups, FEAD and EuRIC. The regulation, adopted in July 2023 by the European Council,
sets a 2027 implementation requirement for manufacturers of portable appliances tofeature replaceable batteries that can be easily removed by the end-user. The
regulation’s scope covers smartphones and tablets, electric bikes and e-scooters. The
regulations will ramp up over time.
We set out to test policy options in the consumer research, including the potential fordeposit return options.

4.7 AwarenessThe requirement to raise awareness of battery recycling in the UK was introduced as partof the Waste Batteries and Accumulators Regulations 2009. This legislation
implemented the EU Battery Directive in the United Kingdom and became effective on
May 1, 2009. The directive aimed to minimize the environmental impact of waste
batteries and accumulators by establishing rules for their collection, recycling, andproper disposal.
One of the key aspects of these regulations was the focus on increasing publicawareness of battery recycling. Producers and distributors of batteries were required tolabel their products with specific information regarding recycling and proper disposal.
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The labels were intended to inform consumers about the importance of recycling
batteries and provide guidance on how to do so.
The awareness-raising requirements were designed to encourage responsible disposal
practices and contribute to the reduction of environmental pollution caused by improper
disposal of batteries. This emphasis on public awareness aligns with the broader
principles of extended producer responsibility, where producers share responsibility forthe environmental impact of their products throughout the entire lifecycle.
We set out to test awareness of how to dispose of batteries, the dangers of batteries andconsumer campaigns aimed at raising awareness in the consumer research.

4.8 Repairability
While the WEEE Regulations do not specifically require batteries to be repairable, they
do include provisions related to eco-design and environmental performance.
Manufacturers are encouraged to design products, including batteries, withconsideration for environmental impact, energy efficiency, and recyclability. These
principles are in line with the broader concept of Extended Producer Responsibility(EPR), which places responsibility on producers for the environmental impact of theirproducts throughout their lifecycle. The eco-design requirements may involve factors
such as:
1. Material selection: Choosing materials that are environmentally friendly and canbe easily recycled.
2. Energy efficiency: Designing batteries to be energy-efficient during use.
3. Recyclability: Ensuring that batteries are designed to facilitate recycling at theend of their life.
To date, emphasis has been on encouraging environmentally responsible practices
rather than specifically mandating repairability. However, repairability and modularity inproduct design are increasingly becoming topics of interest in the broader context ofsustainable consumption and production.

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4.9 The ‘Right-to-repair’The ‘Right to Repair’ refers to the concept and movement advocating for consumers'
ability to repair and maintain their own devices, rather than being forced to rely on
manufacturers or authorised service providers. This movement seeks to address thechallenges posed by products that are designed in ways that make independent repair
difficult or impractical. The Right to Repair extends to a variety of products, including
electronics, appliances, and even agricultural equipment.
Key aspects of the ‘Right to Repair’ movement include:
1. Access to repair information: Advocates argue that consumers should haveaccess to manuals, guides, and other information necessary to repair theirproducts. This includes details about the device's construction, components,
and troubleshooting procedures.
2. Availability of parts: The movement also calls for manufacturers to makereplacement parts and tools readily available to consumers and independent
repair professionals. This facilitates repairs without having to go throughauthorized channels.
3. Unlocking software and firmware: Some products have software or firmwarethat may hinder independent repair. The Right to Repair movement often calls for
manufacturers to allow consumers to access and modify this software, ensuringthat repairs can be carried out without artificial restrictions.
4. Fair and accessible diagnostics: Consumers should have the ability to diagnose
issues with their devices without proprietary tools or software. Access todiagnostic information allows for a better understanding of the problem andincreases the likelihood of successful repairs.
5. Legislation and regulation: The ‘Right to Repair’ movement has gained traction
in various regions, leading to proposed or enacted legislation. These laws aim toenforce manufacturers' transparency and ensure that consumers have themeans to repair their products.

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6. Environmental impact: Supporting the ‘Right to Repair’ aligns withenvironmental sustainability goals by reducing electronic waste. Repairing andextending the lifespan of products contribute to a more circular economy andlessens the environmental impact of manufacturing and disposal.
7. Consumer empowerment: The movement emphasises the empowerment ofconsumers, allowing them to make informed decisions about the repair,maintenance, and disposal of their possessions. This counters the trend of"throwaway culture" where products are discarded rather than repaired.
The ‘Right to Repair’ movement has gained momentum globally, with various countries
considering or implementing legislation to address these concerns. However, the extent
and success of the movement can vary, and manufacturers may have different stanceson embracing the principles.

4.9.1 Europe
The path towards ‘right to repair’ legislation in the EU has recently taken a major leap
forward with new rules adopted by a significant majority in the European Parliament inApril 2024. The rules aim to reduce waste and make it much easier for consumers toaccess repairs, more cost-effective and supported by extended warranties for repaired
items. Whilst the range of products currently captured by the rules is limited, it can beextended and important includes smaller items including mobile phones as well as larger‘white goods’ such as washing machines.
The European Parliament’s Rapporteur René Repasi said, “Consumers’ right to repair
products will now become a reality. It will be easier and cheaper to repair instead ofpurchase new, expensive items. This is a significant achievement for Parliament and its
commitment to empower consumers in the fight against climate change. The newlegislation extends legal guarantees by 12 months when opting for repair, gives better
access to spare parts and ensures easier, cheaper and faster repair.”Member States will have to promote repair, including offering vouchers, runningpromotional campaigns or providing repair spaces.

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4.9.2 California
California has been a notable player in the ‘Right to Repair’ movement in the UnitedStates. However, the status of ‘Right to Repair’ legislation can change, and further
developments may have occurred since our review.
In 2020, the California State Assembly introduced Assembly Bill 1163, also known as theCalifornia Right to Repair Act. The bill aimed to require original equipment manufacturers(OEMs) to provide owners and independent repair businesses fair and reasonable
access to service information, tools, and parts to repair electronic equipment.
The key provisions of AB-1163 included:•••

Access to Information: Manufacturers were required to make available to the
public, owners, and independent repair providers the same diagnostic and repair
information provided to their authorized repair providers.
Access to Parts: Manufacturers were obliged to offer parts, including any updates
to the parts, to owners and independent repair providers at the same price andterms offered to authorized repair providers.
Software and Documentation: Manufacturers were required to make available toowners and independent repair providers any embedded software and firmware,
as well as any updates, for diagnosis, repair, or lawful modification of the device.

4.9.3 United Kingdom‘Right to Repair’ has been gaining momentum in the United Kingdom, focusing on theneed for consumers to have the ability to repair their own devices. At its heart is theconsumer and delivering better value for money spent on what can in some cases besignificant purchases; as a result, the right to repair reduces and in some cases
eliminates waste by increasing a product’s life by up to ten years.
New legislation introduced in 2022 aligns the UK with the EU, where the same legislation
came into effect in March 2021.
•

manufacturers of certain types of electrical equipment (primarily ‘white goods’
such as washing machines, washer-dryers, dishwashers, fridges, as well as
televisions and displays) are now legally required to provide consumers with

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•

•

•
•

spare parts for ‘simple and safe’ repairs, and more complex parts available totrades/professional repair organisations
non-consumer electronics including lamps, motors, supermarket refrigerators,
vending machines transformers and welding equipment are also covered;however cookers, tumble dryers, microwaves, laptops and smartphones
unfortunately are not covered by the legislation
spare parts must be made available for seven years (more in some cases) after a
product has been discontinued; the list of spare parts does not include batteries(as these are not present in most if not all of the appliances covered by current
legislation, e.g. cordless vacuum cleaners are not included)
in most cases, new devices must be sold with a repair manual to enable simple
repairs by consumers
appliances must be designed in such a way that they can be dismantled using
conventional tools.

According to the Government, this should reduce the amount of electrical waste
produced each year, estimated at 1.5 million tonnes.
In addition, Eco-Design requirement have also been considered in the UK that would
encourage manufacturers to design products with longer lifespans, easier repairability,and better recyclability. These requirements are part of broader efforts to transition
toward a circular economy, however, are yet to gain traction.
We set out to test attitudes to repairability in the consumer focus group.

4.10 Vapes, scooters, e-bikes, cars and Parliament
Recently, disposable, single-use vapes have been in the spotlight. In many ways, thesedevices sum up the current challenges, and policy failure, around batteries, resource
efficiency, producer responsibility and safety regulations. With very few restrictions on
their sale and use, limited or no consideration of the environmental (not to mention
health) consequences and no meaningful producer responsibility enforcement at theend of (their very short and rather pointless) life, clear dangers have literally been
designed into the system.
A recent report by Material Focus reported by The Guardian estimates that at least 1.3
million disposable vapes are thrown away in the UK every week – the equivalent of two
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vapes per second. It would seem from reports that the Government is currently focusedon measures to make producers improve the design of products and fund recycling.
Refillable, reusable vapes have existed for some years and are clearly less problematic,
and can be better managed in use and at the end of life, not least through take-backschemes at specialist shops; however this ‘engagement’ and opportunity for exchange
doesn’t take place with single use, disposable vapes which are instead discarded in thenearest bin, hedge or gutter.
MPs were separately trying to push through legislation although this initially stalled,having run out of parliamentary time. However, single use vapes, which will be banned in
the UK as part of plans to tackle the rise in youth vaping and protect children’s health,the Prime Minister announced on 29 January 2024 on a visit to a school. It is notable thatthe legislation notes the impact vapes have on the environment noting that “five million
disposable vapes are thrown away each week, up from 1.3 million from last year. Over a
year, this is equivalent to the lithium batteries of 5,000 electric vehicles.”More recently, ‘The Safety of Electric-Powered Micromobility Vehicles and Lithium
Batteries Bill’ has been drafted and is supported by Lord Foster along with several
organisations including the Fire Chiefs Council, RoSPA, National Housing Federation andmany others, including the CIWM and ESA. The Bill seeks to ensure that the Government“make regulations regarding the safe disposal of lithium batteries” and regulate the saleof e-scooters and e-bikes, tightening up current ‘self-declaration’ by manufacturers. The
accompanying briefing note highlights the fact that fires caused by lithium-ion batteries
in e-scooters and e-bikes have quadrupled since 2020. It goes on to state that the UK isfacing nearly one such fire per day, and that there are more than 200 landfill fires in the
UK each year, making up almost half of all fires and costing £158m annually.
On 6 December 2023, the Office of Product Safety and Standards issued a Government
Safety Message on e-bikes and e-scooters. The message focused on e-bike and escooter use and charging, and does not mention how to dispose of batteries and seems
to be lacking a ‘Step 6: NEVER dispose of a battery in the same bin as your regular rubbish
or recycling as they can cause a fire’. However, the accompanying safety information
briefing issued by Fire England does cover disposal, stating:

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Batteries – the need for a new approach towards Extended Producer ResponsibilityDisposing of a lithium-ion battery
Lithium-ion batteries should not be placed in the same bins as your regularrubbish or recycling. They can cause a fire if they overheat or when crushed
in bin lorries or waste and recycling plants.
You can find out how to dispose of your lithium-ion battery safely by checking
your local authority's website for information about the safe disposal ofbatteries in your area or you can find your nearest recycling centre at:www.recycleyourelectricals.org.uk

4.11 Taking responsibility – bikes
The Bicycle Association has made publicly available resources for the industry to assist
with safe sourcing of batteries, their correct transport and storage. They are also piloting
a battery collection and recycling scheme which will take waste batteries from retailers
at no cost for safe and proper disposal and have worked with the Association of Cycle
Traders to assist the cycling industry and charity Electrical Safety First in raisingawareness of the fires issue and advocating urgent Government action.
The Bicycle Association’s initiative is a great example of an organisation and sector
taking responsibility and working with manufacturers to ensure a lowest-cost system isin place to support retailers and consumers, removing the burden from local authoritiesof what could become a significant challenge in the future as e-mobility grows, driven inpart by the net-zero transition and encouragement of people to get ‘on their bike’ to help
reduce local congestion, air pollution and carbon emissions.

4.12 Clothes
Recently, heated clothing has hit the streets, with the phenomenon starting in workwear
and spreading to more general retailers. This winter (2023/24) these products havebecome much more widespread in the UK.
These garments have a built-in heating elements (e.g. made from carbon fibre strips) andfor more recognised brands, generally include wiring and a pocket for the battery, but nobattery or charger, which are sold separately.

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Mainstream outdoor wear and workwear brand Regatta isleading the charge with a wide array of jackets
incorporating the technology, with 25+ different jackets
from fashion to hi-vis. Screwfix, Sports Direct andmultiple workwear suppliers stock Regatta heatedjackets, along with Regatta’s own online store. These
jackets sell at premium prices, alongside compatible
rechargeable batteries and charging systems – although
the user can use their own compatible battery pack.
Figure 5: MIEVNIO battery-powered heated hat

A search on Amazon for ‘electric hat’ returned over
350 results and 570 results for ‘heated hats’ (electric hats includes hats containing techsuch as headlights). Many are sold with batteries included or even incorporated into thegarment.
The cheapest was a yellow beanie hat available in a range of colours with an integrated
rechargeable headlight including battery, made from soft acrylic and sold for £8.49.

The most expensive was a £155 MIEVNIO battery heated cap made from polyester andelastane sold with a 2200mAh lithium-ion battery and AC charger. There is no point-ofsale advice over batteries or battery disposal visible.
On eBay, electric heated beanie hats with USB rechargeable connections were available
from under £20, in many cases batteries were not included. There were 1,700 results for‘heated hat’ and 948 results for ‘electric hat’.
A search on Google for ‘electric hat’ returned 482,000,000 results and ‘heated hats’63,800,000 results.
These garments will be entering the municipal and workplace waste streams in the
coming months and years, and in many cases include batteries, presenting a challenge
not just for waste collectors but also clothing recyclers including clothing banks in car
parks/stores.

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4.13 Hope – cars
For some products, ensuring recycling solutions for batteries is becoming essential,
before and beyond regulations, driven instead by supply and demand. A recent article inWaste Management World reported that “eighteen times as much lithium will be neededby 2030 as today, and sixty times as much by 2050. The demand for cobalt will increase
fivefold by 2030 and fifteenfold by 2050.”
It notes a study by the Fraunhofer Institute which estimates the existing capacity forbattery recycling in Europe is around 33,000 tonnes per year, predicting the volume oflithium-ion batteries and battery components to be recycled across Europe is set to riseto 300,000 tonnes per year by 2030, and 1.5M tonnes per year by 2040.
We set out to test awareness to the dangers of batteries through the consumer research.

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5 Attitudes and awareness: survey sector and public

attitudes

5.1 The Narrative
With EU policy evolving, wide acceptance by consumers of the need for companies toaddress environmental and social challenges, the drive for ever-smarter (and seemingly
cheaper) embedded tech and adoption of battery-powered tech across society, it isessential that this problem is addressed.
The UK’s ongoing review of end-of-life battery requirements presents an opportunity tounderstand, test, interpret and influence views and potential direction of policy in the UK.
Post-Brexit, the UK has an exceptional opportunity to treasure the rare-earth materials
being transported and imported into the UK, materials we have low or no reserves of,which could provide the country’s growing tech sector with many of the raw materials it
requires for the technology revolution, for international competitiveness and for thedevelopment of innovation and new technology.
All we need now are the right set of extended producer responsibility requirements,
targeted at solving the right issues in the most effective and sustainable ways, with a nod
to future-proofing in order to keep up with technological innovation and consumer
behaviour, whilst seizing the opportunity presented by the valuable materials available
in the proliferation of batteries and potential for servitisation here in the UK.
So we asked consumers what they think, what’s important and how best to solve theproblem.

5.2 Methodology
The following consumer and industry research was undertaken in two phases:
Phase 1: CIWM short stakeholder survey and discussion group round table event held in
Birmingham in September 2023.

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This phase was adapted and conducted by a short survey testing key issues, aimed
at those affected by policy and potential changes to policy. The questionnaire can beviewed in Appendix A, and a summary of the results is set out below. The
questionnaire was promoted via CIWM’s online platform and Linked In.
We also held an initial round table discussion with stakeholders reflecting CIWM’s
membership representing a range of activities from operations, consultancy, safety
and compliance.
Phase 2: Consumer research (2,064 adults) carried out in September 2023 and a
consumer focus group (20 participants) held in Bournemouth in October 2023
The purpose of this phase was to provide a robust assessment of the existing ‘stateof play’ with respect to existing consumer behaviours, motivations and barriers. The
survey was delivered using online panels that are proprietary and used solely formarket research purposes. To ensure statistical surety and confidence in thefindings, we targeted a sample of 2,000+ UK citizens. Quotas targets were used – onage and gender (interlocked), region, working status and ethnicity - to ensure that the
profile of the sample matches the known profile of the UK population.
We asked a series of 12 high level questions exploring existing behaviours, attitudes
and knowledge, plus additional socio-demographic profiling to explore how answers
vary across, for example, different age or income cohort.
In addition to the survey, the consumer work also included an additional phase ofqualitative research to provide more granularity. Rather than retracing the steps
taken in the survey, this instead focused on how citizens feel about current andfuture policy, and the best way forward from their perspective.
Rather than a typical focus group, we will conduct an extended evening workshop
lasting two hours and taking on the form of a ‘citizens summit’ style event.
Participants will be initially presented with information about the issue and be asked
to work together collaboratively to identify appropriate solutions. Participants work
together and bounce ideas off each other to arrive at more considered
recommendations.
The workshop involved c. 20 participants, with recruitment undertaken according toa strict questionnaire. Central to the design of the questionnaire was the choice ofPage 39 of 76
Batteries – the need for a new approach towards Extended Producer Responsibilityscreening filters (i.e. to exclude certain individuals from attending) and quotas (i.e.
to establish the composition in the groups). Participants were paid a £65 ‘thank you’for attending.
All fieldwork was conducted to the recognised standards of the UK Market ResearchSociety Code of Conduct and in line with two international quality accreditations ISO 20252 (the Market Research Specific standard) and ISO 27001 (the Data andInformation Security standard).
The key findings from both phases of the research are set out below.

5.3 Results of engagement with CIWM members andsector stakeholders (Phase 1)
5.3.1 Questions 5 & 6 – awareness of correct disposal
All of the industry stakeholders who responded to the questionnaire were aware of how
best to dispose of batteries and the key issues/impacts affecting the sector.

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5.3.2 Question 9 - biggest barriers

Comments made by the industry stakeholder responders included:“I get the feeling that nobody much in government cares and although manysupermarkets do provide battery collection points there is no publicity nor are
instructions given to ensure that the public is aware of the consequences interms of fire, damage to the environment, and child safety of not disposing ofbatteries responsibly.”“People are confused about what to do and don't understand the dangers ofincorrect battery disposal. There are limited options for recycling. It is too easy
to dispose of batteries in municipal collections, either due to ignorance orlaziness. Waste permitting can actually limit collection options, especially for
hazardous waste.”“Legislation needs to be more serious, and encourage companies to innovate
business models to take back / make it easier to recycle / etc. Consumers need
to be incentivised to be more responsible with purchases and EoL. It would be
helpful to have LiPo take-back centres that were near / collected periodically.”“Inability to remove/replace batteries from artefacts. Inability to refurbish
batteries for reuse. Inability to dismantle batteries to reuse the parts . Lack of
local services to collect and recycle. Battery design does not consider its future
recyclability.”
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5.3.3 Question 10 – the most important things to fix withrespect to addressing the hazards presented by incorrect
battery disposal
The responses to this question included:“Consistent guidance
regions/companies.”

andrecycling

opportunities

acrossdifferent“Promote the risks and make it easy to recycle batteries.”“Education of the public / communications at point of purchase.”“Good segregation.”“Have a battery collection scheme once a year.”“Make it easier for consumers to return batteries. Maybe have specialised collection
periodically (e.g. two months) alongside normal household collections?”“Legislation to make all companies ensure they do not sell products that will cause
harm due to the use of batteries. It makes no sense at all for irresponsible companies
to be able to create products which cost the public purse to clean up later.”“Making it socially unacceptable to incorrectly dispose of batteries, much likesmoking has been made socially unacceptable.”“Market pull for end of life batteries.”

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5.3.4 Question 11 - do you think a deposit return scheme forbatteries could provide a solution?

Comments made by the responders included:“It would have to be backed up by some pretty heavy penalties for non-complianceand to be publicised at a high degree of spending that I don't [see] any government
with the same policies as the current government showing the remotest chance ofspending.”“How would those items be marked? Why my question? I think, that if that scheme
would be introduced, there would be hight number of people, who would collectitems from residential bins, so they can bring it to a retailer and get those
forementioned £2. So I think that there should be some sort of marking on items
introduced to the market once the DRS would be implemented, otherwise theretailers could struggle with keeping up with payments.”“This would also help Local Authorities which are currently responsible for the costof collection and recycling, and are likely the most affected by battery fires.”“I'm not a fan of DRS for packaging (massive duplication of existing waste collection)
but do see merits for batteries. As long as it is not a big burden on small retailers, well
worth exploring.”

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“Perhaps begin the campaign with things which are a 'no-brainer', and then allow themore nuanced/tricky items to come in later years. It would need some incentives forindustry to get this flywheel going.”“It would need to be combined with improved battery design to enable thecomponents to be recycled or the battery refurbished and reused. DRS works for
consumable in which the container has a value and is readily reused or recycled .
Batteries are currently not readily recycled or reusable.”“Consumers won't do it , have a return deal via Amazon.”“More drop off points, increased incentive through take back scheme or DRS.”“Consumers would be unlikely to return small items typically seen as disposable likerechargeable toothbrushes.”“All SMW (small mixed WEEE) should be designed so that the batteries can beremoved. Consumers can then be rewarded for returning batteries to collection
points based on weight or number returned.”“Perhaps a blanket fee levied on all products placed on the market containing aremovable rechargeable battery with increased compliance fees for those that donot, similar to the scaled incentives packaging manufacturers have to increase
recycled plastic content in their products.”“It would only work for specific items and whilst reducing the risk, would notnecessarily address the whole market issues.”

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5.3.5 Question 13 – vapes, what action should be taken

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5.4 Results of consumer research on existing consumer
behaviours, motivations and barriers (Phase 2)
5.4.1 Levels of ownership5.4.2 Disposal

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This was also reflected in the citizen workshop, with participants feeling they need more
information about how best to dispose of these items. Comments included:“I literally have an electric toothbrush at home that I’m not sure what to do with.”“They [the council] don’t let you know what to do with any of these items.”“Can I put them [power packs] in with the battery collection at the supermarket?”
Disposal routes were found to vary by item – the general rubbish is significant forrechargeable vapes and electric toothbrushes; the HWRC for power tools, power packcharges and rechargeable toys; and there is greater use of trade in/selling on for
smartphones, tablets and computers.

This was also reflected in the citizens’ workshop:
For items perceived to have financial value, many would consider trade in/part exchangeor selling. However, data concerns (and a lack of knowledge about how to safely remove
personal data) are a barrier for some.

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The larger the item, the more disposal is consciously considered. They are often taken to
the HWRC when they are perceived to be at the end of their life.
Smaller and/or lower value items are often disposed of in the general rubbish (although
the recycling collection is also considered/used where there is awareness).
Because of the closer natural association with batteries, some try to recycle power packs
front of store (while others opt for the general rubbish).
Many respondents conceded they have lots of items at home not in use (i.e. in drawers).
The environment was a motivator for around half, although convenience and financial
pay-off have wider appeal.
Comments made by participants included:“For a smartphone I’d try online trade in or selling it. It’s convenient and you’re also
getting some money back for it.”“For an old electric toothbrush I’d just throw it in the bin and not think twice.”“But if the council collected it in the recycling, like that lady said, I’d do that instead.”
Disposal knowledge influences disposal choices. For standard batteries, those who are
confident they know how to best dispose of them often opt for front of store; those notconfident often opt for the general rubbish.

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Page 49 of 76
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The link between disposal knowledge and disposal choices is present across all items.
For rechargeable toothbrushes, those who are confident they know how to best disposeof them often opt for the HWRC; those not confident again often opt for the generalrubbishFor items like smartphones and computers/laptops, better disposal knowledge
increases the propensity to use routes such as selling, trade in, retailer take back and the
HWRC.

5.4.3 Awareness of problems

Gaps in awareness are evident across all sub-groups (although there is somewhat higher
awareness among those aged 55+, those with a higher university qualification and thosein social grade AB). Those who say they recall the Take Charge campaign report thehighest levels of awareness. The same is true (to a lesser extent) among those who say
recycling is very important to them.
The citizens’ workshop provides evidence of some emerging knowledge about the safetyissues of specific devices:
Some, for example, had already seen media coverage of electric scooters catching fire.
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Others noted experiences of battery packs being removed on safety grounds at airport
check in while travelling in Asia or the US (but not in the UK).
One participant had personal experiences, including a laptop catching fire in theworkplace after being left charging all night.
Coverage of phones liable to overheating also helps to establish awareness (even if thisappears to be conceptualised as a performance issue and not liable to cause an actual
fire.
Comments made by the participants included:“There’s a lot in the news about scooter fires.”“The recycling infrastructure hasn’t caught up with the products on sale now.”“Now I think about it, everything’s got a battery inside it. I’ve had a power bank taken
off me at the airport because they said it was too powerful and a safety risk.”
But this awareness isn’t yet a comprehensive or systematic narrative about lithium
batteries.
There is a default sense for many that items will automatically stop charging once theyreach full charge.
Some find it confusing because products appear designed to be permanently charging
when at rest (e.g. cordless vacuum cleaners sat in the docking station that is plugged in).
There is some evidence of ‘lazy’ charging behaviours where devices are just left plugged
in all the time when at home, especially phones.
Most concerns about leaving things plugged in - prior to the workshop – were framed interms of performance (e.g. the possible impact on device/battery performance and life
whereas a re-framing towards safety might be more persuasive.
Supporting comments made by the participants included:

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“But when it gets to 100%, doesn’t it just stop charging?”“I just plug my phone in overnight and go to sleep.”“I do have my rechargeable lithium batteries for work charging on a fire-proof slateboard (because they can be volatile). But I don’t really think about the devices thathave them built in.”
The videos and examples shown at the workshop had a strong ‘shock’ impact that madeseveral participants immediately reconsider some behaviours.
Many participants immediately related the safety issues to their own products andbehaviours, as well as to the things they put in their bin.
The fact that fires caused by batteries are so difficult to put out was a concern.
The “maximum number of charges” was a useful articulation for some, and led to anumber of immediate concerns (e.g. handing down their smartphone to their
granddaughter, or buying refurbished, or buying an electric car, might not be as good achoice as they first thought it was).
Supporting comments made by the participants included:“I’m petrified, it seems that anything can explode at any time.”“Now the phone warning about overheating makes sense and is scary.”“The main message I took away was don’t leave things plugged in.”
While there is acknowledgement that citizens can play their part, there is frustration that
this is limited by how products are designed:
There is a feeling that manufacturers don’t want consumers to be able to replacebatteries, because this would increase product lifetimes and decrease how often newdevices are purchased.
The majority wouldn’t know how to separate out the battery from their products.
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Batteries – the need for a new approach towards Extended Producer ResponsibilityNo one mentioned product advice or instructions, and there was a feeling that this issmall print that is less important and not designed to be widely read.
Supporting comments made by the participants included:“How would this (removing battery) work for a toothbrush? It’s injection moulded.”“They should design products to be accessible during their life, and to be separated
and recovered at the end of their life. But it’s very difficult to replace a battery or
separate it before disposing of the product. They’re encased in plastic or metal.”

5.4.4 Recall of, and reaction to, the ‘Take Charge’ campaign

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None of the participants in the citizen workshop recalled this campaign; but reactions
were positive. This asset was positively received, subject to the following critique.

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Batteries – the need for a new approach towards Extended Producer ResponsibilityIn general, this was considered useful, short and to the point.
However, there was a sense it needs more direct, unequivocal guidance on where to put
them (as opposed to lots of conditions about ‘do this if you can; if not do that…).
As per previous feelings about how realistic it is to ask citizens to remove batteries, there
was some push back to this request.
Some noted it could be made more eye catching (e.g. colour scheme, images of productswith batteries, images of fire).
As a general point (that applies throughout) there needs to be a stronger focus that it’sreferring to batteries IN things, not just typical batteries.
Some noted that the campaign logo reminds them of the musical group Take That.

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Reactions to the zombie theme of the campaign were positive (visual stand out, amusing,cleverly done), although a number of suggestions were made to improve it.
The main criticism is that it does not spell out why they can be ”lethal”, with no mentionof fire risk (either to themselves or at the HWRC).
Some suggested more about fires. There was a sense it needs more “shock value” (in linewith some of the videos shown in the workshop).
There was also a sense (based on this asset alone) that the campaign is all aboutstandard batteries (as per the image here) rather than batteries inside of products.
Comments made by the participants included:“It’s not clear enough it’s dangerous. Could they put fire in the background.”“I liked the concept of zombie batteries. But if you don’t know they set on fire, what
does it mean, they’re back for revenge?”

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The flow chart was (not surprisingly) one of the assets less well received, because of thelevel of content and – once again – the lack of a clear answer and lots of conditions.
“No-one uses flow charts. We produce endless ones at work and I don’t know anyone
who refers to them.”“I got lost and bored with the flow chart.”
The logo also did not test well in the citizen workshop. While the general ethos of a‘warning label’ is familiar, it is felt to represent standard batteries once again, as opposed
to batteries inside of products. And it is not intuitively clear enough the battery can causea fire. Comments included:“The icon doesn’t work as it implies a standard AA
battery, whereas it’s rechargeable batteries inside ofthings, like your phone, which are the issue here.”“To me it kind of says ’don’t throw batteries in fires.”5.4.5 A DRS for batteries

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In the citizen workshop, respondents asked a number of questions as they probed theidea:• how much would it increase the price of the item?
• would the deposit be on the item or the battery inside?
• if the retailer/brand went out of business, could they still reclaim the deposit?
• would it increase levels of theft by making it more attractive to steal and sell?
Through the discussion (which was relatively preliminary), the following insights andpreferences emerged:
1. It would work best if levied on the battery itself (in turn meaning that a DRS wouldintersect with the movement towards eco-design and right to repair).
2. It would work better on smaller and low value items (given that routes alreadyexist to get value back from items like smartphones; and these lower value items
don’t have any sensitive personal data on them, removing a potential barrier toparticipating in a scheme.
Supporting comments from the participants included:“I think it may increase theft and give criminals an extra incentive.”
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“If I can’t wipe it [data] then I’d be hesitant about giving it away to this kind of
scheme.”“I think the whole concept of our right to repair should be championed.”

5.4.6 Vapes / e-cigarettes
The survey demonstrates that one in seven (14%) adults in the UK uses a vape/ecigarette. This includes 8% who use a rechargeable vape, 7% a refillable vape and 5% asingle use vape.
The survey also demonstrates that, for rechargeable vapes (NB. the survey did not ask
about disposal vapes), the dominant disposal routes are the general rubbish bin (24% of
rechargeable vape users typically dispose of it this way) and the HWRC (23%), followed
by a dedicated council collection (13%).

Turning to views on the best policy responses to disposable vapes, there was strong
support for restrictions or an outright ban, even among the vape users themselves. Thiswas based on two elements:
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1. Health concerns. Especially for younger age groups, who were felt to be targetedby the industry. Some felt that vapes had led to non-smoking children/young
adults becoming addicted to them (as opposed to the original intention of helping
existing smokers to quit).
2. The waste and litter implications. Single use vapes were felt to encapsulate the“throwaway society”. The fact that every vape has a small battery inside thatwould ultimately never be recovered was felt to be a waste of resources, even
without the secondary risk of fires that participants had become more aware of in
the course of the discussions.
Comments from the participants included:“They are marketed as harmless but they’re not.”“I would ban vapes because of the impact on children. A by-product would be theenvironmental benefit.”“What a waste of a battery. That’s phenomenal.”

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6 Conclusions
The United Kingdom is still trying to bury the problem of hard-to-recycle products andmaterials, less often in landfill (it is 2024 after all!), more often by either pretending there
isn’t a problem, hoping a magical solution turns up to save the day or physically sending
them ‘away’ to somewhere else where out of sight is definitely out of mind.
The problems are significant; the funding to solve the problem is not. We think these
problems are ‘away’ but they are coming home to roost.
Often, ‘away’ is someone else’s ‘home’. A beach in Ghana covered in British clothes.
Villagers in India melting the plastic off wires and circuits to recover rare and precious
metals from British e-waste.
‘Away’ is full, broken, changing. ‘Away’ has had enough.
And we – us, here – we know we need to do better; we know we can. We need our words
to be heard through our actions.
Britain must lead by example and accept responsibility for the products and materials it
consumes. Businesses must step up and take responsibility for the impact of the
products and materials they import, make, use and sell here.
The problems are increasingly closer to home than we might think. Fires caused bypowerful rechargeable batteries in cheap gadgets or even in clothes have increased
dramatically, putting lives in danger – the lives of our colleagues, members of CIWM.
And the rivers and oceans we are so inspired by contain increasing amounts of plastic,
entering food chains and ultimately us – humans. There is no doubt we have entered the
Anthropocene – where humankind has exerted a lasting, and potentially irreversible,
influence on the planet’s systems, environment, processes, and biodiversity.

6.1 So why an ‘EPR of everything’?
Where does responsibility lie for “cleaning up society’s mess”?

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Presently, all roads lead to local authorities, who are left holding the fort. But local
authorities should be the last resort, focused on protecting human health and theenvironment, not the front line for anything producers choose to throw at them. Surely, it
was never the intention for local authorities to become international commodity traders(and try to do it in 400 different ways).
As ably supported as they are by waste, recycling and resource management companies,
combined our front line CIWM colleagues don’t stand a chance when faced with thebarrage of increasingly complex and often dangerous materials making up products witha rapidly diminishing life expectancy.
In some, indeed in many cases local authorities may be best placed to collect, toprocess; however this must be funded and individuals and organisations must accept
responsibility for their impacts. We all have a duty of care but ultimately, accountability
should fall on those responsible for producing and putting products on the market, and
who are in the position to influence and specify designs and materials which areconsistent with the concept of a circular economy – its design, longevity, repairability,
resilience, safety and recyclability.
The end-of-life impact of products and materials cannot be a carefree and unconscious
process by those carefully and consciously exploiting raw materials.
The OECD definition of EPR is ‘an environmental policy approach in which a producer’s
responsibility for a product is extended to the post-consumer stage of a product’s life
cycle’, and typically characterised by:
1. the shifting of responsibility (physically and/or economically; fully or partially)
upstream toward the producer and away from municipalities; and2. the provision of incentives to producers to take into account environmental
considerations when designing their products.
Whilst EPR should be the default position there is a hierarchy of need with products suchas batteries, WEEE, and textiles the most important to have EPR regulations applied tothem as soon as possible. These products are causing the greatest and most urgent
concern from multiple perspectives, particularly from a people safety and planetaryimpact perspective.

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6.2 So let’s talk about deposits
Often and in large part due to a complete lack of communication or any ongoing
relationship with the consumer since the point of purchase, decisions over how torecycle or dispose of a product have to be made by the consumer at the end of a
product’s life. This could be moments or indeed many months or even years after
purchase.
Deposit return schemes may not be every producer’s or retailer’s cup of tea, but they are
an extremely important mechanism in joining up the point of purchase and the point ofrecycling or disposal decision – they keep the consumer and the manufacturer
connected; they provide an in-built call-to-action. Deposits have an important role toplay.
Critical to what happens next, and ending the fallacy of ‘away’, is a change of attitudes,
behaviours and cultures, in which deposits can play an important, efficient and effectiverole. An urgent, systemic review of who should do what is required. It should be irrelevant‘who’ currently collects an item or a category of products: it has to be about the best
outcome, the best way, making the right decisions.
This needs leadership in order to drive it, and it needs to be outcomes focused. It needs
to start right now. The transition to circularity will require what’s sacred to be discussed,
not getting hung up on ‘business as usual’ – open minded by default.
Prevention – avoiding the creation of waste, and reducing the amount andhazardousness of waste – is an essential element of the EPR of everything. EPR policy
needs to drive better design, better execution of purpose, better resource efficiency
through extended life where possible, and of course much better provision for thecollection, reprocessing and incorporation of materials back into new products.
This needs to be fully funded through producer responsibility and driven by targets and,
where necessary, taxes and levies.

6.3 Cost versus Value – changing the narrative
A frequent criticism levelled at EPR and deposit return schemes is that they place costburdens onto citizens, a factor that is accentuated by the current cost of living crisis.
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However, the debate is actually about consumer value for money. It’s about cost versus
value. Cost, where an item is considered ‘a bargain’ because it is cheap, may not offer
the best value compared to another item which has, let’s say, a 20% price premium but
is designed to last twice as long. The ‘cost per use’ is much better.
Consumers have been trained into believing ‘cheap’ is equal to ‘value’ – however, cheap
is often poor value for money. An argument against EPR is that it will increase the cost to
the consumer: the consumer pays the price eventually, but the costs of ‘cheap’ arehidden.
The real price of a cheap electrical product where the rechargeable batteries cannot be
removed or replaced is the cost of damage to Refuse Collection Vehicles, damage towaste and recycling facilities, installation of increasingly elaborate fire detection
systems, a 500% increase in insurance premiums, additional complexity of kerbside
collection schemes in an attempt to collect the nth this or that forced onto local
authorities with no market for the end product and no funding to support schemes. And
the cost to the consumer of buying another one; repeat as above.
All of this extra cost is paid by the consumers – primarily by council taxpayers throughincreased costs (or felt through a reduction in recycling or other council services, wherethat is the only choice open to a municipal authority).
Deposits do not add cost to the consumer. They add complexity to ‘Business as Usual’operations for manufacturers and retailers, which may require short term investment tooperationalise. However, deposits, as part of a wider EPR scheme, also drive attitudes,
behaviours and cultures, both of consumers and of manufacturers and retailers. They
drive innovation and invention. They drive investment. They drive domestic capacity andeven manufacturing.
They drive value for money for the consumer, aka the council taxpayer, aka the voter. And
they help to protect human health and the environment, at home and ‘away’.

6.4 So why start with batteries?
Fires caused by batteries are a crisis for the resources and waste sector, for taxpayers,
for homeowners, and for Government. Addressing the problem is an emergency, and an

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Batteries – the need for a new approach towards Extended Producer Responsibilityemergency response is required. Batteries are a perfect candidate for extended producer
responsibility and a deposit return scheme.
There were more than 1,200 fires caused by or suspected to have been caused bybatteries at UK waste and recycling sites and vehicles in 2023 (Material Focus, 2024), an
increase of 71% from 2022. These are batteries – in particular, high-powered,rechargeable batteries – that should not have been put in a bin, which should instead
have been taken to a collection point.
The cost of the damage and lost time from these unacceptable and entirely avoidable
fires caused by batteries is estimated at £158 million in annual damages (Eunomia,2021). Fortunately, so far no-one has been killed in any of these incidents however clearly
there is significant concern that this fortune may run out.
There are three reasons why these high-powered rechargeable batteries are ending up in
bins – the wrong waste in the wrong place:
1. Clear and impactful information on how to correctly dispose of used batteries
is not reaching consumers at point-of-sale or disposal and consumerawareness of the hazards is low due to a lack of funding for campaigns;
2. Batteries are finding their way into more and more everyday items, from singleuse vapes to toys and gadgets and even into clothes and shoes, andconsumers may be unaware an item even contains a battery;
3. Producer responsibility rules have not kept up with changing chemistry andpervasiveness of technology, with little or no incentive for manufacturers or
retailers to change, placing the burden of cost onto local authorities.
Championing extended producer responsibility, and supporting the sector’s transition toa circular and net zero economy are key commitments for CIWM – along with promoting
safety for colleagues and consumer value for money.
This is why we are starting with batteries.
Our consumer research shows that the public are concerned over the impact and dangerof batteries, are keen to do the right thing and strongly support action for change.

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There is a lack of knowledge, information and confidence amongst consumers on how todispose of batteries and gadgets that may contain batteries. This is particularly
problematic in relation to cheaper/lower value and smaller items, such as vapes andrechargeable toothbrushes, whereas higher-value items are more likely to be traded inor sold on, with fewer ending up in a bin.
Where batteries can be removed and replaced, i.e. traditional ‘AA’ batteries, they aremuch more likely to be taken back to a retailer or other collection point – by almost 70%
of people.
By contrast, higher value or larger items are more likely to be traded or otherwise taken
to a Household Waste & Recycling Centre (HWRC). Breaking this down for typicalexample items, the charts below show that the degree of confidence an individual may
have does not necessarily follow through into markedly improved outcomes, showing alack of information reaching consumers due to low point-of-sale and disposal cutthrough.
The public are ‘petrified’ when they discover the true impact of putting the wrong waste
in the wrong place, in this case a battery or an item containing a battery in the bin.
Our research indicates that the public strongly support the use of deposits for items likebatteries. The level of deposit doesn’t need to be very high or set at a percentage of thevalue of a product, because the big-ticket items when it comes to ‘wrong waste – wrong
place’ are cheaper, smaller products such as vapes and toothbrushes.

6.5 We need a new deal for consumers
Continuing with ‘business as usual’ is unacceptable and change must happen in orderthat this urgent crisis for our industry, for taxpayers and for Government can beaddressed.
1. Battery manufacturers and retailers need to act immediately and work with the
CIWM to promote safer, simpler recycling, ensure ‘the right waste in the rightplace’ and celebrate success, such as measures being put in place by the Bicycle
Association to collect e-bike batteries, which make the problem and solutions
more visible.

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It is great to see voluntary schemes being implemented which take the issue ofbatteries, battery disposal and battery safety seriously and it is exactly these sortsof schemes that should become mandatory under EPR.
2. Chemistry-specific targets must be brought in and introduced as part of theprocess of updating existing battery producer responsibility legislation to an EPR
for batteries, as a matter of urgency to ensure consumers can access collection
points and industry-funded take-back schemes for high-powered rechargeable
batteries and items containing these batteries – lead acid batteries account for
70% of recycling evidence but are just 3% of the UK market.
Currently compliance is a box-ticking exercise – targets are being easily met at theexpense of disincentivising investment in capacity to handle and recycle non-leadacid batteries. This is a quirk of the current out-of-date regulations and needs
reviewing urgently, however this amendment to the current regulations is only aquick fix to address the current emergency situation being caused by batteries; it
is not a long-term solution.
3. Work should start immediately on a deposit-return scheme for batteries which
our research shows the public strongly supports this measure and the problem
items are generally smaller/cheaper where a modest deposit will have the highest
impact.
We think a modest, flat rate deposit on all batteries or items containing batteries
would be simple and effective, targeting the most problematic products andspurring action to address the issues flagged above. Retailers and manufacturers
would need to ensure battery collections or collection points were available.
Deposits would have the additional effect of challenging manufacturers to comeup with better product designs, drive more products to have removeable andreplaceable batteries and bring about the beginning of the end of designed-in
obsolescence dictated by battery life. This would vastly improve safety of
products at the end-of-life, reducing the risk to CIWM members and the public,
and improve value for money through repairability.
4. Support needs to galvanise around the development of domestic rare-earthmaterial circularity and tech circularity businesses – this is not about amending
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end-of-life regulations, but a fundamental shift in attitudes from ‘cost’ to ‘value’
through right-to-repair and eco-design principles.
With global demand for rare earths materials expected to reach 466,000te by2035, up from 170,000te in 2022, clearly there is demand for these materials.
Urgent Government action is needed to support R&D investment in rare-earthmaterial recycling.
Combined with the above points, the UK should lead by example and move frombeing one of the most wasteful societies in the world when it comes to electricaland electronic equipment, to become one of the most progressive andresourceful, respecting the safety of others and grasping the opportunity
presented by mining the urban environment for valuable materials, supporting
manufacturing and export, creating jobs and skills as a result.
CIWM is taking a lead on the issues end-of-life batteries are having on workers within the
Resource & Waste sector, and the lost opportunity that this currently presents as an
example of why EPR needs to be extended. CIWM is:•••standing up for consumers
protecting workers in the resources and waste sector
safeguarding critical raw material and driving the UK towards a more circular
economy.

Ultimately, we see a clear path towards ‘EPR of Everything’ as a policy priority area,
focusing on materials, products and sectors where either there is no current or direct
producer responsibility code or requirement, or where what does exist has demonstrably
fallen short in delivery or fallen behind current technology, policy or practice as is thecase with batteries.

6.6 CIWM’s “New Deal for Consumers” in detail
Regulatory and legislative measures, combined with the attitudes of better informed andmotivated consumers, act as positive drivers for change.

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Some commentators will no doubt try to counter this by stating, as they have in relation
to packaging EPR changes, that “it is unfair on consumers for Government to be adding
to ‘the cost-of-living crisis’ by introducing environmental taxes,” and use this as an
excuse for inaction.
However, this is misguided and serves only to obfuscate from the real issue – cheap
goods with built-in obsolescence are having a huge impact on peoples’ quality of life bymaking people pay multiple times for something like an electric toothbrush or a t-shirtthat should last a lifetime.
And the double-whammy is that council tax bills are going up because of the pressures
to collect more and more difficult waste streams, and pay for the damage to vehicles andfacilities used by local authorities to manage recycling and waste.
Deposit-return schemes and EPR schemes are not a tax on goods – they are the opposite,
serving to highlight system failures (‘bads’), direct the right waste to the right place andsupport better value for consumers.
EPR should be used positively to ensure value for money for consumers and taxpayers:
by ensuring sufficient funding is in place for collection and processing of products andmaterials; by increasing the ‘in-use’ phase for example through better design,
warranties, repairability; and through innovation and servitisation to eliminate waste andimprove resource efficiency.
Making things that last longer is key. Think of it in terms of cost-per-use. The cost-per-use
of an item manufactured to last twice as long as a similar product will most likely makemore sense as long as it is less than double the price. For more expensive products,
servitisation (where an item is leased rather than purchased, and maintained as part ofthe deal), may make more sense.
These business models have existed in the past and still exist today for some purchases
and products; our prediction is that they will make a come-back and should beconsidered more widely. We believe these models will be developed as a consequenceof delivering EPR – there are already strong signals in key market sectors including white
goods, lighting, furniture and clothing.
Our report shows that action on batteries should be targeted:
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•
•

•
•

•

clear and unambiguous definitions for battery types and categories to prevent thecurrent lead-acid imbalance
problem products tend to be lower-value, smaller items e.g. rechargeable
toothbrushes, vapes etc, not higher value, expensive or large items, e.g.
smartphone, laptop, cordless garden tools
place a flat-rate deposit on batteries or products containing batteries, e.g. £2
potential for an eco-design ‘levy’ on products where currently batteries cannot be
removed or replaced, as an incentive to producers to improve design and/or toconsumers to buy a different product in lieu of inaction by manufacturers
unclaimed deposits/levy income should be used to promote research anddevelopment – these should be cost-neutral as the objective must be to set up
systems for success… EPR should be there to cover collection/recycling costs.

By encouraging removable batteries and supporting the right to repair, products will bebetter made e.g. motors will have to last several battery-life cycles and/or be repairable
too, ensuring products last longer and offer consumers better value-for-money.
CIWM supports the expansion of take-back schemes which are the right approach tosupport the mission of ‘simpler recycling’:•••

making the problem and solution visible to consumers;
ensuring the producer pays; andenabling the management of deposit scheme administration and levy collection(collected for and on behalf of the exchequer at point of sale, akin to VAT).

Whilst this will interrupt ‘Business as Usual’ and be mildly inconvenient for retailers andmanufacturers, it’s much less inconvenient than setting fire to vehicles and facilities
used to manage society’s waste and recycling.

6.7 CIWM’s support for developing circular economy
opportunities
Alongside these measures, it is essential that the scarce and expensive critical raw
materials (CRM) in batteries are captured for the current and future generations,providing readily accessible materials for the UK economy.

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The narrative must be changed to support a circular economy not just for these materials
but also for the products they are used in. There are significant potential economic
benefits from CRM infrastructure investment in the UK and the first step is to invest in
domestic battery recycling capacity, especially when linked to freeports and facing
outwards to Europe and beyond.
This is supported by CIWM’s ambitions to assist members and the wider UK economy totransition to a circular economy as a key driver of, and agent of change in, supporting thedrive towards net-zero and the modernisation of our industry from waste to resources,
adding significant value to the sector.

6.8 Vapes – a salutary lesson
Vapes are a microcosm of everything that is wrong with the way new products are placedon the market without any consideration for end of life management.
They also perfectly demonstrate the consequences of incorrect disposal, and the lack of
any EPR requirement with real teeth which essentially has placed all responsibility on thewaste management industry and local authorities.
It was completely predictable. We must not allow this sort of mistake to happen again.
The survey for this report demonstrates that one in seven (14%) adults in the UK uses avape/e-cigarette. This includes 8% who use a rechargeable vape, 7% a refillable vape and
5% a single use vape.
The survey also demonstrates that, for rechargeable vapes (NB. the survey did not ask
about disposal vapes), the dominant disposal routes are the general rubbish bin (24% of
rechargeable vape users typically dispose of it this way) and the HWRC (23%), followed
by a dedicated council collection (13%).
The field work did not consider single use vapes, which will be banned in the UK as partof plans to tackle the rise in youth vaping and protect children’s health, the Prime
Minister announced on 29 January 2024 on a visit to a school.

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6.9 Closing comments
The impacts of selling cheap, single-use plastic items containing a non-rechargeable,
single-use battery were entirely foreseeable. The same is true of embedding powerful,rechargeable batteries inside electrical and electronic products – making themremoveable and replaceable is the minimum requirement.
The experience with disposable vapes demonstrates that the problems were entirely
foreseeable but that we will have had to wait around a decade, facing a growing problem,
before legislation finally catches up.
It cannot be allowed to happen with clothing and aftermarket bike parts, both of which
are increasingly appearing in general waste containing high-powered, rechargeable
batteries.
Moreover, the wider issues explored in this paper are compounded by the fact thatoverseas ‘away’ solutions’ days are numbered. The Textile Recycling Association (TRA)
have “sounded the alarm about the imminent collapse of the textile recycling sector”
due to global market challenges and a tightening of regulations in Europe.
This is despite warnings issued by TRA over two years earlier. The main impact will, ofcourse, be on local authorities, charity shops and recycling collection companies, not on
retailers and manufacturers.
We must ensure we use our foresight to never make the same mistakes again.

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Appendix A

CIWM Industry Questionnaire – BatteriesThis industry survey is being conducted on behalf of the Chartered Institution of Wastes
Management by contractor John Twitchen as part of a wider project looking into the challenges
and opportunities presented by batteries, in particular high-powered, rechargeable Lithium-ion
batteries and batteries embedded in other products, e.g. rechargeable electrical equipment.
This survey will inform the direction of the report and recommendations, and is complemented
by an industry round table which is planned to be held in mid-October in Birmingham. If you
would be interested in attending the round table, please ensure you complete the last question sothat we can contact you.
Results of the survey will be anonymised for use in the final report; views will not be attributed
to individuals or organisations. If you have any questions about the survey, you can contact John
Twitchen via johntwitchen@gmail.com or Richard Hudson via richard.hudson@ciwm.co.uk - wethank you for your time and consideration of these important issues.
1. Your name (confidential - the answer to this question will not be shared or published)
2. Your organisation (confidential - the answer to this question will not be shared or published)
3. Describe the main activity(ies) of your organisation. Choose all that apply.
•
•
•
•
•
•
•
•
•
•
•
•

Waste management
Waste/recycling collection
Consultancy
Compliance
Policy development
Communications/PR
Planning
Finance/insurance
SafetyEquipment
Construction
Other

4. Have you or your organisation been affected by a fire or other incident caused by batteries? Select
one.
•
•
•

Yes – once/very rarely
Yes – often
No – never

5. To what extent do you feel that you you’ve been given enough information to know how tocorrectly dispose of batteries? Select one.

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•
•
•
•

Definitely know how to correctly dispose of batteries
Fairly sure I know how to correctly dispose of batteries
Not completely sure I know how to correctly dispose of batteries
Not sure at all/unclear how to correctly dispose of batteries

6. How would you dispose of the following items?
Put inhouseholdrubbish or
recycling bin

Leave it forsomeoneelse toclean upTake to
HWRC

Donateit/give it
away

Sell it/
trade itin

Take toaretailer

Other(specify)

Rechargeable
toothbrushElectric scooter
Lap top
Single use
vape
7. Do you recall seeing the 'Zombie Batteries' campaign?

•
•
•

Yes
Possibly/think so
No

8. What do you feel are the main issues with battery recycling (practice, regulations, infrastructure etc)
in the UK at the moment? Please include any examples.
9. In a word or phrase, what are the biggest barriers to improving battery recycling in the UK? Pleasepick up to three.
•
•
•
•
•
•
•
•

Poor/no collection
Lack of take-back schemes/locations
Communications/promotion
Compliance schemes
Government
Regulations fit for purpose
Retailers
Waste management/recycling companies

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•
•
•
•

Lack of demand/lack of markets for recycling
Consumers
Manufacturers
Other

10. What do you feel is the most important thing to concentrate on that will fix the problem and address
the hazards presented by incorrect disposal of batteries? Give examples; references welcome.
11. Thinking about the future, we would like your views on a proposition and then ask your opinion
about. Industry colleagues will most likely be familiar with the concept of a Deposit Return Scheme.
One option would be to introduce a Deposit Return Scheme for batteries – including standard batteries
as well as rechargeable batteries within products like smartphones, electric toothbrushes, etc. It would
work something like as follows:
➢
➢

➢
➢

People pay a deposit when buying a product [with a rechargeable battery inside]. This would
be added to the price of the product.
They return the product at the end of its life and get their deposit back; or if the battery isremovable, they return the battery and swap it for a replacement. It doesn’t need to be thesame place where it was bought from.
Different methods of returning items are possible. For example, ‘return points’ could be via asupermarket or retailer take back scheme.
If the product is not returned to one of these return points, the deposit is lost.

As an example: you buy an electric toothbrush which costs £15, which includes a £2 refundable
deposit. On returning the product you get the £2 back, so the product has only cost you £13. If you
didn’t return the product to a designated return point you would lose the £2.
Do you think a deposit return scheme for batteries could provide a solution?
•
•
•
•
•

Yes – definitely
Possibly/think so
Maybe – for some types of batteries
No – not at all
PLUS: Please provide any views you may want to share on the potential for a Deposit Return
Scheme for batteries.

12. Have vapes - single-use/disposables, rechargeable/reusables - caused you any difficulties? If yes,
please describe.
13. What do you feel should be done to address the immediate issue of disposable vapes containing
batteries?
•
•
•
•
•

Immediate ban on sale and import
Ban on sale near to schools
Industry take-back scheme should be introduced immediately
Should only be available from chemists/on prescription
Nothing, not a problem

14. Final question: would you be interested in attending the industry round table on batteries,
scheduled for Birmingham in mid-October? If yes, please provide your email address (confidential - theanswer to this question will not be shared or published).

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