Can business batteries go in the bin? What UK regulations actually say
Business batteries can’t go in general waste. Here’s which UK regulations apply, which paperwork you need for each battery type, and how to check a collection partner.
If your batteries need replacing, or you've unintentionally built up a stockpile of used ones, you might be wondering what to do with them. Can business batteries go in the general waste in the UK?
The short answer is no: batteries should never go in the bin. Because of their chemical makeup, batteries present risks if you dispose of them with the rest of your waste. They require special care, meaning you should enlist a battery collection partner who understands how to handle them safely and legally.
Batteries are classified as controlled waste – household, commercial and industrial waste that is subject to the Environmental Protection Act (EPA) 1990. Under Section 34 of this act, all businesses must take reasonable steps to dispose of their controlled waste without harming the environment.
This is because when thrown in the bin, batteries pose a risk to both human and environmental health. As they break down over time, the chemicals inside batteries can leak out into the soil and water, causing pollution and harming wildlife. Similarly, hazardous heavy metals such as lead, mercury, and cadmium can transfer from the battery into the surrounding environment.
A third and more immediate risk is that a number of conditions including overheating, moisture, and being crushed can cause lithium-ion batteries to catch fire in landfills or bin lorries.
The primary waste battery regulation in the UK is the EPA 1990 mentioned above. The duty of care outlined in Section 34 of this act states that controlled waste must be transferred to a registered waste carrier and disposed of at a permitted facility.
Another key regulation when it comes to batteries is the Waste Batteries and Accumulators Regulations 2009 (SI 2009/890), which lays out responsibilities for producers and distributors. It explains that automotive battery producers must offer to collect waste batteries free of charge from businesses such as garages.
It also states that retailers and distributors must accept waste batteries for recycling if they sell 32kg or more of portable batteries per year. Importantly, this does not apply to businesses who simply use batteries in their own operations.
The WEEE Regulations 2013 don't apply to stand-alone batteries. But many batteries are contained within WEEE, such as old laptops or mobile phones.
In this case, the waste is covered by the regulation, meaning that it must be disposed of like all e-waste: passed on to a registered waste carrier and taken to an approved authorised treatment facility (AATF).
When the equipment is treated at an AATF, the batteries will be removed, where they’ll then fall under the separate battery regulations and must be sent to an Approved Battery Treatment Operator (ABTO).
The paperwork you’ll need to keep in order to be compliant with the above regulations varies depending on your battery type – namely, whether it’s hazardous or not. This is set out in the List of Wastes (England) Regulations 2005 (SI 2005/895), Schedule 1, Chapter 16 06.
Based on the European Waste Catalogue (EWC), this gives every type of waste a six-digit code, and marks all hazardous waste with an asterisk (*).
Under the EWC classification, lead-acid (16 06 01*), nickel-cadmium (16 06 02*), and mercury-containing (16 06 03*) batteries are labelled as hazardous.
If you’re disposing of these types of batteries, you’ll need a consignment note as proof you have upheld your duty of care. This goes beyond a standard waste transfer note as it requires detail on the chemical properties of the hazardous waste and records every movement of the waste. It also must be preserved for a full three years.
Alkaline (16 06 04) and lithium (16 06 05) batteries, on the other hand, are classed as non-hazardous. Their disposal requires a standard waste transfer note that you must keep for two years.
However, when you dispose of a batch of batteries, they aren’t likely to be separated by type – both hazardous and non-hazardous types will be jumbled together. To ensure you dispose of them safely, treat these mixed types as hazardous and follow the regulations accordingly.
While classed as non-hazardous waste in the List of Wastes, lithium’s high fire risk means that this type of battery is marked as dangerous goods for transport under the ADR; a separate set of rules governing the transport of dangerous goods by road.
You should therefore confirm that the company you contract to collect your waste batteries is compliant with ADR requirements, which involves packaging them safely, marking them with warning labels and ensuring the driver has undergone emergency training.
The procedures around waste battery disposal may seem complicated, but you can be sure you have fulfilled your duty of care so long as you choose the right collection partner.
The checklist you should assess potential partners against includes:
For the peace of mind that you’re working with a partner who meets all of these criteria, speak to GAP about commercial battery disposal.
Book a free review with our team. We'll look at how your organisation disposes of electricals today and show you exactly where your documentation falls short.