About this market review

In this portable battery market report, we provide a high-level overview of progress in achieving the indicative 2021 UK battery obligation. We also consider how new guidance to advise on the classification of batteries may impact upon this in 2021, and more significantly, in subsequent compliance periods.

Progress in achieving the UK 2021 portable battery obligation

As can be seen from the table below, the UK is on track to meet its indicative 2021 battery obligation, having collected 58% of the current annual requirement in Quarters One and Two 2021.

Battery obligation on track

Achievement of the 2021 targets currently seems likely, particularly since the quantity of waste battery collections reported is usually higher in the second six months of each year than in the first six months. Although the quantity of portable batteries placed on the market is also usually highest in Quarter Four of each year, however, since the obligation is based on the current compliance year and the previous two compliance years, the increase in waste battery collections in the latter part of the year, typically exceeds the increase in obligation.

New guidance published jointly by Defra, the Office for Products and Safety Standards, and the Environment Agency on 31^st August 2021 (explained further below) may impact on the final 2021 UK battery obligation. The reason for this is that some batteries currently classed as industrial or automotive may instead require reporting as portable batteries in Quarters Three and Four of 2021.

 New battery classification guidance

Before the new guidance, a battery was classed as portable if it weighed 4kg or less, was sealed, and was not an industrial or automotive battery. Whilst this remains unchanged, the publication of criteria as to what constitutes a sealed battery and when batteries may be reported as industrial batteries because they are considered as being designed exclusively for industrial or professional use, may alter how batteries are classified.

The new guidance states that batteries are unlikely to be considered designed exclusively for industrial or professional use if they are available for the general public to buy, or, can be used across a wide variety of items across a range of sectors.

A sealed battery is defined as a cell which remains closed and does not release either gas or liquid when operated within the limits specified by the manufacturer. This means that batteries fitted with a safety device to vent for safety purposes only, are sealed batteries, and where the other criteria above apply, are classed as portable batteries.

Potential impact of the new battery obligation guidance to producers

The new guidance is widely expected to increase the weight of batteries that are reported as portable batteries. Since the 2021 battery obligation is based on the average weight of portable batteries placed on the market in each of 2019, 2020 and 2021, the impact of the new guidance on the UK obligation may not necessarily be material in 2021. However, it is important to understand the potential impact of this in the future since it may increase:

• alignment between portable lead-acid batteries placed on the market and waste portable lead-acid batteries collected;
• the UK portable battery obligation and consequently, the quantity of waste portable batteries producers are collectively required to finance;
• and the cost of collecting and treating those batteries. This is since any increase in obligation may necessitate collection of a wider range of batteries to achieve compliance.

In conclusion

Finally, we understand that the Defra consultation on the review of the Waste Batteries and Accumulators Regulations, which will potentially implement further changes to this regime, including increasingly detailed reporting at battery chemistry level, will commence in 2022. We look forward to engaging with Defra and our other stakeholders on this.