Legislation forcing producers to declare all batteries placed onto the UK market - even if they are destined for export - is resulting in an obligation to recycle batteries even when they are no longer available in the UK.
Currently, batteries are declared by producers based on being placed onto the UK market.
But Robbie Staniforth, key account specialist at batteries compliance scheme Budget Pack, told MRW that there is no provision for excluding batteries that a producer subsequently exports from their declarations.
In many cases, this means that batteries due for export attract a recycling obligation in the UK even though they will not be available for recycling.
Furthermore, producers still have an obligation to recycle the batteries in the country to which they export, which causes a double counting of batteries placed onto the market, according to Staniforth.
He also said that although producers are asked to voluntarily provide information on the amount of batteries they export, this information does not reduce their obligation to recycle the exported batteries.
“It is our experience that because this is voluntary and has no immediate effect on a producer’s obligation, the figures reported are significantly lower, thus not highlighting the extent of the issue,” he said.
He added that another side effect of the problem is that it prevents the increase of recycling of household batteries. This also causes a rise in the recycling requirements of lead-acid batteries.
Defra reviewed the issue in April, inviting ideas for developing a more coherent regulatory approach across the different Producer Responsibility regimes.
A Defra spokesperson told MRW: “We have proposed that batteries that are destined for export should not count towards the battery recycling target. We will consult further on these proposals in due course.”
In its summary of stakeholder responses published in September 2013, 48% of respondents called for exported products to be excluded from obligations.
The document said excluding exports should reduce the costs for businesses who export their products.