Diving For Batteries: How to Ensure Embedded Batteries Are Properly Recycled

Consumers demand slick portable electric devices that support their yearn for mobility. To meet this request, product designers have created items that require small batteries with high energy density. Oftentimes, the batteries in these products are molded into devices, preventing consumers from replacing them. Mobile phones, laptops and tablets are sold based on their thin, lightweight design, which in virtually all cases, do not allow consumers to replace batteries in the product.

The evolution of these products has had huge consequences on their end-of-life management, particularly for the proper handling of batteries. To examine the public policy impact of this trend, Call2Recycle commissioned a study by Kelleher Environmental on the implications on battery collection and recycling of embedded battery products.

Historically, for the purposes of recycling, batteries have always been considered a separate material, even though their sole purpose is to power another device. The roots of this are based on the recognition that batteries of the 1980s often contained metals of concern including lead, cadmium and mercury and therefore needed special handling. Today, consumer devices are not powered by batteries containing these metals (although lead batteries are still widely used in certain non-consumer applications). Almost all laws around the world on recycling and extended producer responsibility (EPR) still separately address batteries.

The Kelleher study looked at battery recycling in the U.S. and Canada and attempted to weigh the consequences of embedded batteries on safety, collections, recycling rate, measurement and end-of-life management. The report concluded that:

• Current EPR laws do not recognize the potential overlap in obligated products (where one obligated product may contain two or more obligated materials), particularly batteries contained in or embedded in electronics, and do not have in place clearly defined mechanisms to share, reimburse or coordinate efforts when these products overlap, or one product contains two or more obligated materials.
• As an example, batteries that are embedded in electronics may be properly managed and tracked by the entities managing them at end-of-life, but end-of-life management pathways and destinations are not required to be publicly reported. E-Waste companies are generally not required to report battery collections and recycling efforts as part of their end-of-life management of electronic products even though these companies track this information internally.
• E-Waste certifications appear to require less rigorous tracking and reporting of the end-of-life destinations of batteries in products.
• Embedded batteries cannot be practically the responsibility of battery EPR programs since they cannot generally be safely removed by anyone except highly qualified parties. They must be easily removable by the consumer (so that the consumer can take them to a battery EPR program drop-off) for them to be appropriately the responsibility of battery EPR programs.
• Batteries of all sorts are often being considered for reuse. This end-of-life pathway is not being reported, tracked or regulated by any program or certification at this time.

The Kelleher study further pointed out that EPR laws need to be updated to reflect these key market developments, even though the process to pass laws to update these issues is often slow and cumbersome.  The report also noted that technology developments will allow batteries to be increasingly embedded into products, resulting in more confusion and difficulty in ensuring their proper end-of-life management.

Emerging consumer electronics products, which are becoming more powerful and integrated into our daily lives, will dominate the landscape in the future but their proper management at end-of-life will be increasingly difficult unless there are necessary public policy changes.

By Carl Smith, CEO & President, Call2Recycle, Inc.

To access a summary of the Kelleher Environmental Embedded Battery Report, visit www.call2recycle.org/embeddedbatteryreport