distinction portable-industrial-automotive - eucobat position
DESCRIPTION
Distinction Portable-Industrial-Automotive - Eucobat PositionTRANSCRIPT
Position Paper
Distinction Portable – Industrial – Automotive Batteries
1. The Battery Directive: actual situation
The battery directive1 distinguishes following types of batteries:
• Portable battery or accumulator’ means any battery, button cell, battery pack or accumulator that:
o is sealed; and o can be hand-‐carried; and o is neither an industrial battery or accumulator nor an automotive battery or
accumulator. • Industrial battery or accumulator’ means any battery or accumulator designed for
exclusively industrial or professional uses or used in any type of electric vehicle. • Automotive battery or accumulator’ means any battery or accumulator used for
automotive starter, lighting or ignition power. This distinction is important, as it is decisive to determine the liabilities and responsibilities, as well operational as financial, of all concerned actors. In particular, the significance of the classification of the batteries is undisputable for the calculation of the collection target, as this only applies to portable batteries. After several years of experience in the Member States, it seems that there is particularly a problem to distinguish industrial from portable batteries.
2. Current application of the definitions For the batteries put on the market, the decision on the classification is taken by the producers, based upon a decision tree that is explicitly or tacitly approved by the Member State and that takes into account the criteria described in the battery directive. The decision trees used in the different Member States are similar, with to a larger or smaller extent some interpretative guidance for the producers on the different criteria.
1 Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC – Article 3, 3°-‐5°-‐6°
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For the collected batteries, the operational actors, e.g. sorting or recycling facilities, take the decision on the classification. As one of the criteria to distinguish industrial batteries from portable batteries is the intended use of these batteries (“designed for exclusively industrial or professional uses”), and it is impossible for these operational actors to know the use of the collected battery, they use other criteria, like:
• Weight (varying per country from 1kg to 5 kg) • Collection point (industrial collection points or consumer collection points) • Pro rata (proportion industrial – portable batteries is the same for collection as
for POM) • Sample • … • A mix of these criteria
3. Issues concerning the criteria The producers can relatively easily apply the definitions of the battery directive, as they know in most cases the intended use of the batteries they put on the market. It is however much more difficult for the operational actors to apply these definitions, as they only receive the waste batteries and battery packs, without knowing the applications they were used in. They are obliged to use a set of criteria (see above) that differs from country to country. The different interpretations in the Members States for the classification of the waste batteries into industrial and portable waste batteries have a serious impact on the reported collection rates. As a consequence, these differences make it very difficult to compare the figures of the Member States. Furthermore, experience shows that the application of inappropriate criteria to distinguish the collected batteries leads to unrealistic collection rates in some Member States. Besides the collection rates, the interpretation also influences the financing of the collection schemes in the Member States where multiple compliance organizations coexist.
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4. Eucobat proposal
The main criterion to distinguish portable batteries from industrial batteries in the definitions of the battery directive is of intentional kind (“designed for exclusively industrial or professional uses”), which cannot be determined when the batteries are collected. A full coherence in the classification of the batteries put on the market and the collected batteries can for this reason only be achieved by a fundamental review of these definitions. We are convinced that this will be necessary on the moment of the recast of the battery directive and we will discuss this point within Eucobat and will formulate a proposal. An intermediate solution, standing the current definitions, is required to ensure the comparability of the reported figures of the Member States, with a clear guidance that is easily applicable for the producers and for the operational actors. As indicated, the producers can relatively easily apply the current definitions for the batteries they put on the market, using the existing decision trees. On the other hand, clear interpretation guidance is required for the operational actors for the collected batteries, in order to ensure that these operational actors classify the batteries in the same way as declared by the producers. In order to distinguish portable batteries from industrial waste batteries, the experience of the compliance schemes indicates that a weight limit of 3 kg corresponds to a certain reality and could be used as a first criterion. This appears clearly from a sample in three countries on a typical general household mix of waste batteries collected by the compliance organisations in those countries. The figures indicate that a large majority of the collected batteries from households have a weight till 3 kg.
6a. Definitions P-I-A: Sampling
Weight&per&ba7ery&(kg)& Number&Ba7eries Total&&Weight
0,00&W&1,00& 43% 17% 1,01&W&2,00& 16% 15% 2,01&W&3,00& 27% 35% 3,01&W&4,00& 5% 8% 4,01&W&5,00& 2% 4% 5,01&W&…& 6% 21%
100% 100%
67%&87%&
Belgium&Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00& 96,6%&
1,01&W&2,00& 1,2%&
2,01&W&3,00&
2,1%&3,01&W&4,00&
4,01&W&5,00&
5,01&W&…&
100,0%&
97,8%&
Germany&
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'0,00&W&1,00&
99,9%&1,01&W&2,00&2,01&W&3,00&3,01&W&4,00&
0,1%&4,01&W&5,00&5,01&W&…&
100,0%&
Netherlands&
6a. Definitions P-I-A: Sampling
Weight&per&ba7ery&(kg)& Number&Ba7eries Total&&Weight
0,00&W&1,00& 43% 17% 1,01&W&2,00& 16% 15% 2,01&W&3,00& 27% 35% 3,01&W&4,00& 5% 8% 4,01&W&5,00& 2% 4% 5,01&W&…& 6% 21%
100% 100%
67%&87%&
Belgium&Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'
0,00&W&1,00& 96,6%&
1,01&W&2,00& 1,2%&
2,01&W&3,00&
2,1%&3,01&W&4,00&
4,01&W&5,00&
5,01&W&…&
100,0%&
97,8%&
Germany&
Weight&per&ba7ery&(kg)' Number&of&ba7eries' Total&Weight'0,00&W&1,00&
99,9%&1,01&W&2,00&2,01&W&3,00&3,01&W&4,00&
0,1%&4,01&W&5,00&5,01&W&…&
100,0%&
Netherlands&
6a. Definitions P-I-A: Sampling
Weight'per'ba,ery'(kg)' Number'Ba,eries Total''Weight
0,00';'1,00' 43% 17% 1,01';'2,00' 16% 15% 2,01';'3,00' 27% 35% 3,01';'4,00' 5% 8% 4,01';'5,00' 2% 4% 5,01';'…' 6% 21%
100% 100%
67%'87%'
Belgium'Weight'per'ba,ery'(kg)! Number'of'ba,eries! Total'Weight!
0,00';'1,00' 96,6%'
1,01';'2,00' 1,2%'
2,01';'3,00'
2,1%'3,01';'4,00'
4,01';'5,00'
5,01';'…'
100,0%'
97,8%'
Germany'
Weight'per'ba,ery'(kg)! Number'of'ba,eries! Total'Weight!0,00';'1,00'
99,9%'1,01';'2,00'2,01';'3,00'3,01';'4,00'
0,1%'4,01';'5,00'5,01';'…'
100,0%'
Netherlands'
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However, this weight criterion is not absolute, as some batteries of more than 3 kg that are typically used by consumers and that can be separated based upon the collection channel, should be considered as portable. In order to ensure that the collected batteries are classified in the same way as the batteries put on the market declared by the producers, Eucobat proposes that the batteries above 3 kg that cannot be used by private households are considered industrial batteries.
5. About Eucobat Eucobat aisbl is the European association of national collection schemes for batteries. They assure that all waste batteries are collected and recycled in an ecological sound way, and contribute this way to a better environment. Eucobat aisbl October 2013