Thursday, May 17, 2012

Producer Responsibility for Disposable Batteries

By Bill Sheehan, Executive Director

It has become increasingly clear that the life cycle impacts of the 10 billion disposable batteries produced and discarded around the world each year are significant and problematic.  The battery manufacturers euphemistically refer to these quickly disposable products  as "primary" batteries, which are mostly of the alkaline variety.  They represent 80% of the market for batteries in the United States. 

While alkaline batteries do not contain highly toxic metals like many rechargeable batteries, they do contain dangerous acids, and the metals used also have substantial environmental impacts when considered in aggregate. The European Union has banned the disposal of alkaline batteries and all batteries are to be collected through their producer responsibility electronics directive (WEEE).  Three Canadian provinces have also mandated EPR programs for disposable batteries.  In response, the disposable battery industry is forming a voluntary nationwide stewardship organization to manage alkaline batteries and their kin in the US.

Some history is relevant here.  After bottle deposit laws were passed in the 1970s and 1980s, the next target for producer responsibility legislation in the 1990s was rechargeable batteries – known as "secondary" batteries in industry jargon.  These laws were adopted mostly in states with a lot of trash incineration, like Minnesota, New Jersey and Florida.  In response, the rechargeable battery industry launched a voluntary stewardship organization called the Rechargeable Battery Recycling Corporation.  RBRC gets points for visibility but not for transparency or for accountability for attaining the kind of outcomes established in the legislation that RBRC preempted.  For example, some laws required that 70% of the batteries put on the market must be collected for recycling - RBRC only reports pounds collected, but when regulators looked closely the actual recovery rates, they were in the range of 10 to 20% – and probably still are.

In Canada, new producer responsibility laws that regulate disposable battery collection and recycling have been in place in British Columbia and Ontario since 2010 and in Manitoba since 2011. Quebec’s program will commence this summer.  A new report by CM Consulting, Managing Canada’s Waste Batteries 2012, describes the performance of the programs to date. 

In the United States, the Corporation for Battery Recycling, comprised of the major battery manufacturers in North America -- Duracell, Energizer, Kodak, Panasonic, and Rayovac - are soliciting proposals from organizations to act as the stewardship organization that manages a national program for collecting and recycling disposable household batteries.  The request for proposals will be released in late June 2012.  The national disposable battery recycling program is expected to start in April 2013.

One aspect of the Canadian report mentioned above is especially worth noting in this context.  The report’s author, Clarissa Morawski, is careful to distinguish between different metrics that are often confused: collection, diversion, recovery, recycling, and recycling efficiency (see page 13 of her report). When we talk about the outcomes we hope to achieve with EPR policies, it is important to be clear that we're measuring what matters and that were doing it in a consistent and transparent manner.  Ms. Morawski lays out definitions and methodology that could be applied to a wide range of products and packaging. 

Given the history of the Rechargeable Battery Recycling Corporation, legislators, regulators and other stakeholders should pay close attention to these metrics in assessing the new stewardship organization for disposable batteries.  Proper assessment will determine whether this proposal actually achieves results, or whether further legislation is needed to ensure that it does.

1 comment:

  1. Bill,

    A recent blog of your was forwarded to me for my response.

    Much of it I support. I also am concerned what ultimately will result from CBR’s efforts. However, I have to take issue with one statement that accuses our organization of a lack of transparency.

    In all of the obligated provinces in Canada where we operate, we model a “sold to” denominator in order to calculate collection rates. For those states in the states that seek an estimated collection rate, we provide. ANY municipal, state or other jurisdiction that wants detailed collection information, we provide it. And until states require collections, the best we can do is to estimate.

    Further, take a look at our website. Our annual report provides our complete audited financials and results from the previous year. Plus, our homepage keeps a running tab of batteries collected year to date. Show me a product stewardship organization anywhere that is more transparent.

    Your information is old news. In the last 3 years since I’ve been here, we’ve been an open book.

    Carl E. Smith, LEED® AP
    CEO / President, Call2Recycle®


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