Battery Stewardship Session - PSI Forum 2010
Boston, MA
July 21, 2010
Sponsored by Call2Recycle
The Battery Stewardship Session was part of the PSI National Product Stewardship Forum, at which 100 people
attended in person and over 50 attended via webinar. When viewing these notes, refer to the Battery Stewardship
Briefing Document and PSI PowerPoint presentation from the meeting.
Summary of Meeting Outcomes
There was general participant interest in the following:
1. Continuing to work together to pursue strategies to boost the recycling rate for rechargeable
batteries, including a better understanding of what has been tried, whether it has been
successful, and what additional strategies need to be piloted;
2. Harmonizing existing and future battery laws by developing a model, which should be informed
by understanding which programs are working best in Europe, Canada, and the U.S.; and
3. Learning more about battery lifecycle impacts and making single-use battery recycling more
environmentally beneficial.
Introduction and Session Overview
Scott Cassel (Product Stewardship Institute)
Scott reviewed the proposed issue statement, focus, project goals, and meeting outcome that were developed
based on interviews with stakeholders representing more than 40 agencies, organizations, and companies (see
pages 5-6). As with all PSI meetings, Scott stated that participation in this discussion did not preclude legislative or
other activity by any of the participants. The meeting is an opportunity to discuss potential strategies and develop a
better understanding of the issues related to battery stewardship.
Overview of the Battery Stewardship Briefing Document
Sierra Fletcher (Product Stewardship Institute)
Sierra outlined the Battery Stewardship Briefing Document that was circulated for stakeholder input. The
document was developed based on PSI’s interviews and literature review, and reflects varying perspectives on
the management of batteries and not a unanimous approach. Portable batteries are comprised of two basic
types: single-use (primary) and rechargeable (secondary). Single-use batteries comprise roughly 75% of the
market by weight, although use of rechargeable batteries is growing much faster than that of single-use
batteries. The world battery market is dominated by a small number of companies, many of which make or
market both single-use and rechargeable batteries. Trends in the battery marketplace include the following: (1)
an overall increase in battery sales, (2) phase-out of toxic components, (3) evolving consumer battery
chemistries that can impact battery recycling, and (4) an increased demand for batteries to power hybrid or
electric vehicles and renewable energy installations may impact the consumer battery sector. Seven states and
two local jurisdictions in the U.S. regulate consumer batteries within a product stewardship context. These laws
focus on rechargeable batteries, though some also include older button cell batteries that contained mercury. In
Canada, British Columbia and Ontario require manufacturers to collect all types of batteries, and Manitoba and
Quebec will soon expand their product stewardship programs to include all batteries as well. The European
Union also requires manufacturers of portable batteries to collect and recycle in member countries.
Strategies to Maximize the Collection and Recycling of Secondary Batteries
Carl Smith (Call2Recycle®)
Carl estimated that the rechargeable battery recycling rate for North America is around 10-12 percent.
Call2Recycle® charges companies for the use of their seal, based on unit sales into the North American market.
Call2Recycle® is the first battery recycling program to be certified as an e-Steward by the Basel Action Network,
and operates the longest-running product stewardship system in the country. The organization is implementing
battery recycling product stewardship programs in Ontario and British Columbia for all types of batteries, and
plans to do so for Manitoba and Quebec as well. There are 30,000 Call2Recycle® collection sites around the
country, and 55 million pounds of batteries and cell phones have been recycled since the program started in 1994.
Call2Recycle® implements diverse public education campaigns, accounts for the contents of every box returned
(and contacts the collection site if there are any problems, such as batteries not being bagged or taped), and
provides instructional materials to promote collection site compliance with all federal regulations and
Call2Recycle® operations. Some of the challenges from Call2Recycle®’s perspective are: (1) changing consumer
behavior in a crowded marketplace when batteries represent a small percentage of the waste stream, (2)
maintaining active collection sites, (3) capturing batteries that are contained within products, (4) ensuring
compliance with U.S. DOT regulations, and (5) working within different stewardship program structures.
Priority Strategies: Scott Cassel and Sierra Fletcher (PSI) outlined potential strategies listed in the PSI Battery
Stewardship Briefing Document to increase recycling of rechargeable batteries. Of the strategies presented,
participants were most interested in expanding the collection infrastructure as the key to increasing the collection
of rechargeable batteries. Participants were also interested in the strategy to collect products containing
rechargeable batteries, which is discussed in the “harmonization” section below.
Participants expressed interest in pursuing the following strategies:
1. Require retail collection and specify placement of signage in the window, as in New York City. Encourage
more retailers to voluntarily replicate best practices of Call2Recycle®’s most effective partners, or
include requirements in model legislation. Call2Recycle® cannot mandate that retailers use signage it
provides, although some retailers create their own signage and actively promote the program.
2. Increase the use of Call2Recycle® collection boxes at municipal sites (more HHW facilities, schools,
town/city halls, fire stations, etc.), to replicate the mix of retail and municipal collections in the most
successful programs in Europe.
3. Examine the logistics, costs, and effectiveness of curbside recycling (as done in California, Minnesota,
and Ontario), as well as mail-back, to determine if these strategies should be widely promoted.
4. Examine the logistics, costs, and effectiveness of collecting all batteries together as a way to increase the
collection of rechargeable batteries. Learn from Europe, and, as more data become available, British
Columbia and Ontario.
5. Streamline process (or change regulations) for complying with DOT requirement to bag batteries/tape
terminals, which applies to all lithium batteries, a growing part of the marketplace due to their high
performance and light weight.
6. Increase collection of products that contain rechargeable batteries. It is difficult to enforce the
requirement that most batteries be easily removable, and consumers may not bother to remove them
anyway.
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Participants made the following additional comments:
 Retail collection is more expensive than collecting large quantities of batteries from a business, but
accounts for more than 50 percent of Call2Recycle® collections; it is less expensive than mail-back.
 Emphasize messages at home to remind consumers to recycle batteries (e.g., which kinds/how).
Harmonizing Battery Stewardship Programs
Sierra Fletcher (Product Stewardship Institute)
Battery recycling laws differ in the U.S., Canada, and Europe, which increases the cost of compliance. Session
participants from government and industry supported harmonizing battery legislative terminology/definitions
and developing a model to promote the harmonization of existing and future battery laws in the U.S. Having the
same, or similar, laws would make compliance and enforcement easier, and streamline consumer education.
Although this session did not attempt to reach consensus on the model specifics, participants did affirm each of
the proposed key elements of a model battery stewardship program and expressed a willingness to meet further
to develop such a model. Participants made the following suggestions related to each key program element.
Product scope: PSI suggested a definition that focused on “consumer” rechargeable batteries, but participants
offered several other options. The inclusion of industrial and commercial batteries should be considered, in
particular to align collections in the U.S. with those in Canada and Europe. The term “portable” is used in
Europe. Participants commented that consumers often use the same batteries as commercial and residential
users. For example, the battery in a cell phone is no different if that phone is the property of a large corporation
or an individual citizen. Several participants commented that, in addition to collecting rechargeable batteries,
products that contain rechargeable batteries should be collected as well. The extent to which a state’s e-waste
or cell phone recycling laws address this depends on the scope and performance requirements of those laws.
Responsible party: Participants explored whether “brand owner” refers to the name on the battery or the name
on the product. In some cases, the question is not simple. For example, is Nike or the battery manufacturer
responsible for the battery in a shoe? PSI proposed provisions in Washington’s e-waste law as a model definition
of “responsible party” that considers marketplace complexities. The group did not attempt to reach consensus
on this issue, but agreed that the most important thing is to clearly assign responsibility.
Performance metrics: The group discussed the options presented by PSI. The suggestions from PSI’s Briefing
Document were generally acceptable, although this element requires further discussion. Some participants
expressed an interest in performance goals appearing in legislation, others in regulation or leaving it to the
agency to develop. Still others were more interested in convenience standards that required a collection site to
serve a certain number of people, which they believe are more easily enforced. Penalties for not meeting the
goals raise the stakes considerably. Several participants expressed support for performance goals in Minnesota’s
e-waste law, even though they include penalties.
Reporting requirement: The reporting requirements presented by PSI were generally supported, but it was
suggested that manufacturer reporting requirements should include the type and quantity of batteries sold into
the market to allow for the calculation of a collection rate.
Disposal bans: Disposal bans can be difficult to enforce (especially for small items like batteries) but can be an
important educational tool. Some government agencies do not find disposal bans to be politically acceptable,
while others support them as long as recycling is available. Bans should still be included in the menu of
legislative options for states to consider.
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Enforcement: Enforcement authority should be assigned to a specific agency, but the level and type of penalty
will likely vary depending on the state. Participants stressed that local agencies should have the ability to
enforce state laws on battery recycling.
Processing standards: A battery processing standard similar to the two standards developed for electronics
would provide assurance to government officials that batteries collected in their jurisdictions are properly
managed, especially since they do not have the ability to audit facilities. Currently, no such standard for
batteries exists.
Understanding Issues Related to Managing Single-use Batteries
Michael Babiak (Energizer)
Mike represented the Dry Battery Section of the National Electrical Manufacturers Association (NEMA), and
explained the industry’s sustainability efforts across the battery lifecycle, including reducing the amount and
type of toxic substances in batteries and making them longer-lasting. More recently, NEMA members have
focused on reducing the impacts from battery disposal and recycling. One NEMA lifecycle assessment found that
80 percent of the impact of a single-use battery on the environment happens during the materials extraction
and manufacturing phase, and only 5 percent of the impact is attributed to disposal. The industry is interested in
recycling single-use batteries only if it can be shown to achieve a net environmental benefit, which NEMA
believes has not yet been achieved in the U.S. The DOT regulations factor into the overall analysis, since all
batteries collected for recycling must be bagged or taped, which requires resources to manufacture, distribute,
recycle, or dispose.
Understanding the Lifecycle Impacts of Batteries
Elsa Olivetti (Massachusetts Institute of Technology)
Elsa reported that MIT is conducting a lifecycle assessment (LCA) for NEMA. Once a draft is completed, it will be
peer reviewed, after which it will be made public. The LCA focuses on the lifecycle impacts of an imaginary
“aggregate” consumer alkaline battery used and managed in California. The MIT LCA compares battery disposal
with several recycling scenarios using existing North American battery processing facilities. The environmental
burden associated with recycling options derives from the energy consumed in the actual recycling process, the
number of dedicated trips consumers take to return used batteries and, to a lesser extent, the impact of
transporting the batteries to be processed. As with all product LCAs, the majority of impacts occurs during the
production phase where the most energy is consumed.
Participant Comments
Following the two presentations, participants asked questions and commented on the lifecycle impacts of
batteries and the pros and cons of collecting and recycling single-use batteries. Some participants expressed
interest in an LCA that accounted for additional battery processing facilities, which would be built once laws
were passed that guaranteed all battery collection. Others wanted the LCA to account for curbside collection,
which would eliminate separate trips to drop off batteries.
One manufacturer noted that the industry has been considering battery processing technology that will yield
high-grade materials that can replace virgin materials used to manufacture batteries. This would further offset
the impacts of collecting and transporting batteries to be recycled. Several battery recyclers commented that
they are upgrading and expanding their North American processing capacity in response to the new battery laws
recently enacted in Canada, and in anticipation of the potential passage of legislation in California. They noted
that, although alkaline batteries can be processed in steel mills, a greater percentage of materials can be
recaptured using battery recycling technology already in place in Europe and Canada. One participant asked
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what the supply of used single-use batteries would have to be in order to make investment in the best available
battery processing technology viable in the U.S.
Several participants commented that they are most concerned with clear messaging to the consumer, and that
the message to “recycle all batteries” is the most straightforward and satisfies many consumers’ desire to
recycle batteries rather than dispose of them. Others suggested that collecting all batteries together is a way to
increase the collection of rechargeable batteries (which, in most places in the U.S. today, are a higher priority to
recycle than single-use batteries due to their toxic components.) In Europe, rechargeable battery recycling
increased when all programs started collecting all portable batteries together. One participant expressed
interest in a lifecycle assessment with full transparency and input from diverse stakeholders throughout the
process. Others were interested in understanding the specific factors involved in increasing the net
environmental impact of recycling single-use batteries.
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Proposed Project Focus, Issue Statement, Goals, and Meeting Outcomes
Proposed Project Focus
This project is focused on consumer-type batteries that are used in a wide range of portable devices, including
common household items ranging from calculators and clocks to cameras and flashlights. This project is not
focused on lead acid batteries used in vehicles or small sealed lead acid (SSLA) rechargeable batteries used in a
residential or industrial setting to store power generated from renewable energy installations. In this report, we
use the terms “rechargeable” and “single-use” to refer to the two types of consumer batteries. Rechargeable
batteries are also known as “secondary” batteries, and single-use batteries are also known as “primary” or
“alkaline” batteries.
Proposed Issue Statement
The following issues regarding battery stewardship have been identified as reasons for engaging stakeholders.
These issues are representative of a range of perspectives. They do not represent a consensus among all
stakeholders. Instead, they are indicative of the concerns expressed to PSI staff regarding the management of
batteries.
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Volume/Wasted Resources: Large quantities of batteries are generated and disposed of annually,
wasting material resources and energy.
Toxicity: Rechargeable batteries may contain toxic materials.
Low Recycling Rate: Only an estimated 10-12 percent of rechargeable batteries, and a much smaller
percentage of single-use batteries, are being recycled in the U.S. and Canada. Many batteries are
contained in products that are not recycled, and therefore are disposed of in the trash.
Recycling Cost/Material Value: Single-use battery recycling costs are much greater than recycling costs
for secondary batteries.
Some Imported Single-use Batteries Contain Mercury: Although federal law prohibits the sale of
primary batteries containing added mercury, some batteries manufactured overseas (including those
shipped in products) contain mercury.
Government Cost: Governments must pay to collect and manage consumer batteries that Call2Recycle
does not accept (e.g., button cells and alkaline primary batteries), as well as rechargeable batteries that
are disposed of in the solid waste stream.
Low Consumer Awareness: There is a lack of consumer awareness about the need to recycle certain
batteries and/or where to recycle, as well as a lack of motivation to recycle. Many consumers do not
know the difference between battery types.
Difficulty in Measuring Program Performance: It is difficult to quantify the number of batteries
collected and recycled. Some batteries collected in electronics recycling programs are recycled with the
host product and are not reported, and some battery collection programs do not publicly report their
collection results.
Collection Safety: Recent U.S. Department of Transportation safety regulations require that batteries be
bagged or terminals taped to ensure safe transport. However, these extra steps make collection more
difficult.
Processing Cost: It takes considerable time and resources to separate battery chemistries for processing,
particularly because many battery chemistries are not readily identifiable.
Processing Impacts: There is a need for greater certainty regarding processing practices, and some
believe that environmentally sound recycling standards should be developed.
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Lack of Program Harmonization: Local, state, and provincial laws and/or programs contain different
provisions for scope of batteries covered, performance metrics, reporting requirements, retailer
responsibilities, and other elements.
Proposed Project Goals
Based on stakeholder interviews, PSI proposes the project goals below. The first two goals are focused on
recycling rechargeable batteries, and have an action-orientation. The third goal refers to developing a greater
understanding of lifecycle impacts for all types of batteries, and the fourth goal relates to gaining a greater
understanding of issues related to primary batteries. PSI understands that some participants strongly believe
that primary batteries should be recycled, and that in California, disposal is not a legal option. Other participants
do not believe there is currently a net environmental benefit to recycling single-use batteries in the U.S. The
goals stated below are intended to reflect the status of perspectives regarding battery stewardship in the U.S.
Goal 1: Maximize the collection and recycling of rechargeable batteries.
Goal 2: Harmonize certain elements of battery management laws and recommend critical elements required
for success.
Goal 3: Develop a greater understanding of the lifecycle impacts of batteries on the environment.
Goal 4: Develop a greater understanding of the issues related to managing single-use batteries.
Proposed Meeting Outcomes
Each of the following proposed meeting outcomes correlates to one of the four project goals above. Participants
will leave the meeting on July 21 with the following:
1. A prioritized list of potential strategies that seek to maximize the collection and recycling of
rechargeable batteries in the following areas:
 Collection and processing infrastructure
 Consumer awareness of the problem and how to recycle batteries
 Strategies to motivate consumers to recycle
 Regulatory barriers to increasing battery collection
2. Prioritized recommendations for harmonizing the following elements of a battery product stewardship
program:
 Product scope
 Definition of brand owner
 Performance metrics
 Reporting
 Disposal bans
 Enforcement
3. A greater understanding of the lifecycle impacts of batteries on the environment.
4. A greater understanding of the issues related to managing single-use batteries.
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