Transcript Diapositive 1 - Recharge Batteries

EU Batteries Directive
2006/66/EC
Review
6th. WRBRF - 2015
Berlin, Germany
March 23-24, 2015
PPT 7.
www.rechargebatteries.org
Batteries Directive 2006/66/EC
1.
Portable battery – any battery, button cell, battery pack that is
sealed, can be hand-carried, is neither an industrial nor an automotive
battery
 Collection obligation
2.
Industrial battery – any battery designed for exclusively industrial
or professional uses or used in any type of electric vehicle
 take-back obligation
3.
Automotive battery – any battery used for automotive starter,
lighting or ignition power (SLI)
 Collection obligation
Industrial batteries example:
Batteries used in electrical vehicles, such as electric cars, electric
bicycles, wheelchairs, airport vehicles and automatic transport vehicles
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Batteries Directive 2006/66/EC
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FAQ on the Batteries Directive 2006/66/EC
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Recycling Efficiency guidelines
Recommendations as per position paper of
RECHARGE are reflected in these guidelines
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Recycling Efficiency guidelines
RECHARGE has developed a position paper in October 2012 in order to
secure a clear understanding of the duties and objectives pursued by
Battery producers and recyclers regarding the application of the Batteries
Directive 2006/66/EC and the Commission Regulation (EU) No 493/2012.
The current wording of the EU Commission draft Guidance document on
the Recycling Efficiency Calculation methodology (Article 3 and Annex 1 §
2 of the Commission Regulation (EU) N° 493/2012), requires to achieve a
Recycling Efficiency of 50% at process level, for other batteries and
accumulators, such as Li-ion and Ni-MH batteries.
For industrial batteries, the complete weight of the battery (100%),
including the external jacket, is used to calculate the RE.
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Recycling Efficiency - Reporting
- On an annual basis
- By the recyclers
- To the Member State’s competent
authorities
- No later than 4 months from the
end of a calendar year
- First period: calendar year 2014,
reporting no later than 30
April 2015
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Batteries Directive 2006/66/EC Review
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Batteries Directive 2006/66/EC Review
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Batteries Directive 2006/66/EC Review
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Collection of portable batteries
Source: EPBA (2013)
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Collection of portable batteries: issue
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Issue of mixed flows of Portable & Industrial
RECHARGE proposes not to change any of the current definitions of
automotive, portable, industrial batteries.
In case of need, propose a sub-category for small industrial batteries
(with threshold on weight), allowing the identification of the Producer for
the funding for those small industrial batteries that end up in the
portable batteries flow collected by CRO (not to be paid at POM but only
at time of collection/sorting)
Up to producer to decide (opt-in or opt-out) and to negotiate with CRO.
- Do not request specific revision of the BD for the above.
- Favoring agreements between parties before moving to the
legislative field: start discussions with the CRO’s.
CRO = collection & recycling organization
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Issue of mixed flows of Portable & Industrial
Definition of «small industrial» batteries
Proposed definition for “small industrial batteries” similar to the one of industrial
batteries, only adding the notion of size as for the definition of portable batteries:
“any battery or accumulator designed for exclusively industrial or professional
uses or used in any type of electric vehicle (electric cars, wheelchairs, bicycles,
airport vehicles, automatic transport vehicles,etc...) and that can be hand carried.”
The subcategory of small industrial batteries would be subject to some specific
requirements such as:
a. A reporting obligation to the national authority or a collection scheme such
as for portable batteries; this would include the reporting of units and
weight per chemistry,
b. the reporting would be limited to the quantity sold on the national market;
exports would not be reported.
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Issue of List of Waste - background
o Following a preliminary proposal in 2014, withdrawn in June 2014 , the
review of the List of Waste concerning batteries was proposed during
the last Batteries TAC of the Commission in Dec 2014.
o In December 2014, the annex III of the Waste Directive 2008/98/EC,
which is identifying the properties that makes waste hazardous
according to the CLP classification, has been adopted.
o
It has been proposed to Members State to prepare proposals for
possible input to a new List of Waste before April 2015.
TAC = Technical Adaptation Committee (Member State representation)
CLP = Classification, Labelling, and Packaging of substances &
mixtures (EU Regulation 1272/2008), in alignment to the UN Global
Harmonization System (GHS).
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Issue of List of Waste – Current status
• It seems Austria is still pushing for a change proposal,
following last June withdrawal. It is a possible new “open
box”.
• There is the need to identify the type of hazard applicable for
the transport declaration of hazardous waste (following the
new CLP classification).
• The European Battery Industry will invite the EU
Commission and the Competent Authorities to establish,
together with all concerned stakeholders, a methodology to
properly classify waste batteries and mixtures of various
types of waste batteries in the List of Waste.
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Batteries Directive 2006/66/EC Review
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Batteries Directive 2006/66/EC Review
RECHARGE Position(s) to be further developed on issues
such as:
• When ‘batteries’, Batteries Directive prevails over
other waste legislation
• Portable/industrial definitions
• Collection rates / Available for collection
• Removability
• Labelling
• Recycling Efficiency : specific per chemistry
• Recovery Rate per Metal/Material
• Hazardous substances / List of Waste
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Batteries Directive 2006/66/EC Review
Conclusions
The Batteries Directive Review will be the opportunity for
industry to propose improvements and adaptations to the
current Directive
RECHARGE will likely be involved in the Commission’s
expert working group to assist in preparing such Review.
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Back-up slides
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Battery directive issues: collection targets
Collection objectives: 45% cannot be reached with Li-ion Rechargeable
POM
Collection rate according BD.
Collected
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Collection rate based on «available for collection»
Remaining questions:
- Why is the rchargeable collection lower the primary:
under-estimation of hoarding time?
- Why is Li-ion lower than Ni-Cd: different hoarding time? Less
efficient collection (embedded batteries)?
Carefully assess what we will ask for in the B.D.!
The collection objectives should be based on the availability for
collection, like in WEEE?
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Report of last Commission TAC on List of Waste
FUTURE TAC ACTIVITIES: MODIFICATION OF THE COMMISSION DECISION
2000/532/EC, ESTABLISHING THE LIST OF WASTES.1
Commission Decision 2000/532/EC deals with waste batteries in several ways,
namely as individual waste(s) in chapter number 16 06, "batteries and
accumulators," as well as a part of other waste streams. During the preparation of
the recently adopted modification of this Decision, some Member States proposed
the modification of the codes for waste batteries (see summary attached). It has been
agreed within the Technical Adaptation Committee on Waste that the discussions on
the codes for batteries should be carried out in the meetings taking place under
Article 24 of the Batteries Directive.
The Commission indicated that, within the current system, any modification should
be adopted via an Implementing Decision, requiring the Committee to participate,
although this could change in the future, e.g. requiring for instance the involvement
of the Expert Group.
In order to compile all needed information and as an initial step to consider any
eventual change, the Commission invited Member States to submit their proposals
for changes, accompanied by the information underpinning them. End of April 2015
was proposed as deadline to receive both proposals and related information.
Member States accepted the proposed way of working. The Commission will
propose a way forward (including a possible modification of Decision
2000/532/EC) at the next TAC meeting.
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LoW: Published documents update
Two documents for the description of the hazardous waste:
1
Decision 2000/532/EC on the list of waste pursuant to Directive 2008/98/EC of the
European Parliament and of the Council
New list of waste,
no change for batteries.
2
COMMISSION REGULATION (EU) N° 1357/2014
replacing Annex III to Directive 2008/98/EC of the European Parliament and of the
Council on waste and repealing certain Directives
New annex III= PROPERTIES OF WASTE WHICH RENDER IT HAZARDOUS
Classification according hazardous substances properties (CLP)
The list and the classification are not coherent
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List of Waste- RECHARGE position rationale
• Recognize that all batteries could be classified CLP, as long
as we consider the properties of the substance (case of
unprotected, damaged, mixed types, leaking batteries in
the waste stream).
• Ask for mirror codes for some specific cases:
o when the batteries can be considered as article (no
o
substances release): proved integrity status
When this status can be protected by adapted packaging.
o Offer the possibility to the owner/transporter to use a nonhazardous waste code
o Would also solve the issue of the WEEE containing Li
batteries
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List of Waste- Recharge position
RECHARGE is preparing with EPBA, EBRA, and Eurobat a position for the
Commission.
Key points in the text:
“Indeed, the physical properties of an individual substance contained in an article such as
a battery cannot be used to qualify the properties of the article as the presence of the
substance may be subject to parameters that will govern the properties of the article: e.g. the
concentration of the substance in the article, the chemical, the internal design of the battery,
etc… in addition to the physical confinement offered by the casing.
Due to the diversity, complexity and constant evolution of the composition of batteries and
the wide range of composition observed, it will be justified to include some mirror entry
classifications (both hazardous and not hazardous).
The European Battery Industry, represented by the co-signatories of this letter, invites the
Commission and the Competent Authorities to establish, together with all concerned
stakeholders, a methodology to properly classify waste batteries and mixtures of various
types of waste batteries in the List of Waste.”
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