Dir. Frederik Madsen
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Revised positionpaperThe Battery Association’s The Battery Association’s proposal for a Danish collection and recycling of batteries Third opdated edition March 2003
The Battery Association The Battery Association is the industrial organization for manufactures and importers of batteries in Denmark. The Members of the association are Alkaline Batteries, Danionics, Gillette Group Denmark (Duracell, Hellesens), Panasonic and Varta. The Battery Association represents the European Organization for Batteries, EPBA, in Denmark. Apart from the above mentioned members the members of this organization are: Cegasa, Germanos, GP Batteries, Kodak, Leclanché, Mitsubishi, Rayovac, Renata, Saft, Sanyo and Sony. The Battery Association therefore represents a very important share of the market in Denmark. The 2nd of November 2000 and the 25th of June 2001 the Battery Association made a proposal for the collection and recycling of all used batteries in Denmark. These proposals have now been elaborated and revised in line with the knowledge, that has been created on the area. The background for the proposal to collect batteries 15-20 years ago the attention regarding the collection of batteries was brought about because of the quicksilver, which was and is hazardous for the environment. From the 1st of January 2000 there has been an EU prohibition against quicksilver in batteries, partly thanks to EPBA who played a role in getting that done. Therefore the batteries are no longer hazardous. On the contrary they are now so clean, that they can be recycled in the metal industries. The primary reason for establishing an organized collection is to enable recycling of the raw materials in the batteries in the metal industries rather that having them end on the dumping ground. However, there are also another effect: A few batteries, specially the recyceable nickel-cadmium batteries, still contain heavy metal that must not end up in nature. So far experiences with collection systems for these batteries show that the consumers can not tell the difference between the different types of batteries. We hope that the collection rate including the collection of nickel-cadmium batteries can be higher by giving a simple and clear message to the users: “Return your used batteries”. No to producer liability – for the sake of the environment In Denmark we have an unique waste arrangement, which rest on a fundamental idea concerning waste producer liability. This means that we all are coresponsible for the fact, that the waste are collected and treated correct. Many people talk about, that there has to be a producer liability. Producer liability means, that the producers are responsible for the waste management. Concerning the responsibility it is however so-so, as the expences to the handling is added to the price on the product which means, that it at the end is the consumer, who gets to pay anyway. However the disadvantage with the producer liability first of all is, that a system like this implies that the collection has its own logistic - with the following charging of the environment due to administration, transport, storage etc. We think, that collection of batteries continuously will be a common responsibility, and that it is foolish not to use that logistic, that already is made through the municipal door-to-door collection. No to producer liability does not mean, that we do not participate in a collection arrangement. How we can participate is described later in this paper. We propose that all batteries should be collected Most people associate batteries with the common types - we call them roundcells - which can be bought in the stores. However batteries are much more. There exists a large amount of special batteries that are built in to equipment, where one would hardly guess that the equipment contains batteries e.g. computer equipment that saves the data even if the rechargeable batteries are removed or the power is cut off. Through a link at the Battery Association's website to the Swedish Battery Association you can get a overview of how many different types of batteries there are. Everybody uses batteries and therefore the collection should regard all users: The consumers, the companies and the public authorities. Totally we use approximately 77.000.000 batteries per year. The Battery Association estimates that approximately 87 percent is used in the households and by the public authorities, while around 13 percent is used by the companies e.g. built in to different equipment.
In addition to the above mentioned batteries the rechargeable batteries must be taken into account. The Battery Association feels that it should be a duty for the users to hand in the batteries and that it should be easy to get rid of used batteries. This is supported by an investigation made on the Center for Alternative Samfundsanalyse (CASA), who has made the investigation for the The National Agency of Environmental Protection in order to illuminate the different methods to involve the citizens. The results from this investigation are now written down in the note: "Pilot project concerning methods to involve the citizens in connection with collection of batteries", worked out by Lis Husmer, CASA, Ulf Hjelmer, Gallup and Line Holst Jensen, Greenline Consult. The investigation shows, that the citizens pays very high attention to the fact, that the used batteries toghether with other kinds of waste constitute an environmental problem. The main part of the participants inform, that they return most of their used batteries and only 4-10 percent inform, that they never use the existing collection arrangements. Most people return their used batteries in shops, but generally there exist some uncertainty concerning which shops, that receives theire used batteries. Concerning --- for new collection arrangements, the citizens have the generel wish, that the collection arrangements have to be close to the house. The citizens also wish some national arrangements, so they will not have to require knowledge to different arrangements if they move or spend time in their weekend places. You can find a more indepth summary of the report on batteri.dk - presse - nyhedsbrev no. 4/2002. We suggest that the collection should take place directly at the refuse pail The Battery Association suggests that the batteries should be collected as close to the consumers as possible and the municipalities and santitation departments, who allready handels waste, also will handle the used batteries. On Bornholm they have since January 1st 2002 had the possibility to return used batteries by putting them in a plastic bag, make a knot on the bag and hang the bag on the refuse pail. The arrangement is not only used in single-family houses etc. In the building of flats the inmates can hang their batteries on the container in the courtyard. The arrangement is introduced in connection with a new allocation of a contract concerning collection of garbage on Bornholm as a part of the tender documents and the arrangement has according to the Bornholmske waste company BOFA not been more expensive than the old arrangement. Earlier they collected 8 tons of batteries per year on Bornholm, but with the new arrangement they have collected 11 tons of batteries only from private users. Bornholm has 42.000 inhabitants, which means that every inhabitant collect 255 grammes of batteries per year, which is a very high number, if you compare it with other danish arrangements and if you compare it with other countries. By using that existing transportation and distribution systems and by avoiding unnecessary production, distribution and emptying of collecting boxes other places, than places where there allready exists a renovation arrangement, it is furthermore secured, that the collection charge the environment least possible. Some specialist shops, where changing the batteries is a part of the service are of cource entitled to a possibility to have a collection box, if the shops wants is, but otherwise we do not think that the collection shall take place through collection boxes in the retail distribution. We suggest that the financing should take place through the municipal waste fee Today everybody pays to get rid of their garbage, the households through the municipal waste fee, the public authorities and the companies through payments to a contractor who handles the garbage. Today the municipalities and the companies already use a part of their municipal waste fee to pay different contractors to dispose of used batteries. Thus there already exists a system that finances the disposal of used batteries and we believe that this system should continue. To secure the uniformity in the message, the Battery Association has worked out some information material which can be used in the areas, where the collection of batteries often happens in the shape of a bag on the refuse pail. The information material consists of a logo with a text which can be used in advertisements and booklets etc. Besides that the logo can be delivered as a label, that can be put on posters etc. in shops that sell batteries, and the logo can be delivered to the households to be put directly on the refuse pails. In this connection the Battery Association is also willing to enter a co-operation concerning print of booklet material, that can be used on the battery posters in the shops and in this way be delivered to the costumers. As mentioned the collection of batteries through the garbage has not been more expensive on Bornholm than the earlier arrangement, which did not include batteries, and it may therefore be assumed, that the expenses with a model like this are pretty limited and are not more expensive than the existing arrangements. On this background we abstrain from estimating an amount on the arrangement. Regarding sorting and recycling In order to ensure the cheapest form of recycling an effective sorting of the batteries into different types is necessary. The cheapest form of sorting is sorting mechanically. Experiences in Holland have shown that the quicker the batteries get through the collection system the easier it is to sort them mechanically. However it will always be necessary for the battery garbage to be sorted by hand at first, because the mechanical sorting can not handle damaged batteries, large batteries and objects - garbage that invariably will be part of the disposal. In Denmark we have the advantage that the municipal collection stations are high geared to carry out the first sorting by hand and this system can be maintained. When the project is started most of the batteries will be free of heavy metals, and these batteries can be processed by the metals industry. The problem is that probably there will still be a limited amount of batteries that contain heavy metals and these cannot be processed by the metal industry. Therefore they will have to be sent to other facilities. Batteries that can not be efficiently sorted must be looked upon as enviromentally hazardous refuse with special demands for the processing. We believe that there should be effective methods of controling the goals The aim of the collection scheme is to avoid that the batteries end up in the ordinary day to day refuse. In order to measure the success of the project it will be necessary to examine whether the refuse is contaminated with used batteries in the same way that air polution is measured by means of air testing etc. In Holland methods for examining the quantity of batteries in the waste stream have been developed, and these methods must also be the basis of the evaluation of the project's efficiency in Denmark. Several investigations have shown that the consumers keep new as well as used batteries. This means that trying to determine the quantity of disposed batteries on the basis of sales is subject to a high level of uncertainty. Reservations We would like to bring to your attention that all figures in this document are approximate figures that will have to be worked out with more accuracy. The Danish Battery Association, March 21, 2003 Frederik Madsen The Battery Association's revised positionpaper for the establishment of a collection and recycling of all batteries in Denmark
The Battery Association The Battery Association is the industrial organization for manufacturers and importers of batteries in Denmark. The Members of the association are Alkaline Batteris, Gillette Group Denmark (Duracell, Hellesens), Scansellers (Energizer), Panasonic, Philips and Varta. The Battery Association represents the European organization for batteries, EPBA, in Denmark. Apart from the above mentioned members the members of this organization are: Cegasa, Germanos, GP Batteries, Kodak, Leclanché, Mitsubishi, Rayovac, Renata, Saft, Sanyo and Sony. Thus the Battery Association represents a very important share of the market in Denmark. The 2nd of November 2000 the Battery Association made a proposal for the collection and recycling of all used batteries in Denmark. That proposal has now been elaborated and revised a bit. The background for the proposal (This section corresponds to the section in the original position paper) 15-20 years ago the attention regarding the collection of batteries was brought about because of the quicksilver which was and is hazardous for the enviroment. From the first of January 2000 there has been an EU prohibition against quicksilver in batteries, partly thanks to EPBA who played a part in getting that done. Therefore the batteries are no longer hazardous. On the contrary they are now so clean that they can be recycled in the metal industries. The primary reason for establishing an organized collection is to enable recycling of the raw materials in the batteries in the metal industries rather than having them end on the dumping ground. However there is also another effect: A few batteries, specially the recycleable nickel-cadmium batteries still contain heavy metal that must not end up in nature. So far experiences with collection systems for these batteries show that the consumers can not tell the difference between the different types of batteries. We hope that the collection rate including the collection of nickel-cadmium batteries can be higher by giving a simple and clear mesage to the users: "Return your used batteries". We propose that all batteries should be collected (in this paragraph we have changed the amounts as compared to the original positionpaper) Most people associate batteries with the common types - we call them roundcells - which can be bought in the stores. However batteries are much more. There exists a large amount of special batteries that are built in to equipment, where one would hardly guess that the equipment contains batteries e.g. computer equipment that saves the data even if the rechargeable batteries are removed or the power is cut off. Through a link at the Battery Association's website to the Swedish Battery Association you can get a overview of how many different types of batteries there are. Everybody uses batteries and therefore the collection should regard all users: The consumers, the companies and the public authorities. Totally we use approximately 77.000.000 batteries per year. The Battery Association estimates that approximately 87 percent is used in the households and by the public authorities, while around 13 percent is used by the companies e.g. built in to different equipment.
In addition to the above mentioned batteries the rechargeable batteries must be taken into account. The Battery Association feels that it should be a duty for the users to hand in the batteries and that it should be easy to get rid of used batteries. Eventhough the ambition is that all batteries should be collected, it is necessary to realise that it will not be possible to collect one hundred percent. In Holland they have collected the batteries since 1996, and there the collection rate is 70 percent. The National Agency of Enviromental Proctection and the EU believe that a realistic goal within a few years is 75%. We do not disagree with this goal but we believe it is very high and that it must be considered whether it is environmentally responsible to spend so many resources in reaching 75%. We suggest that the collection take place through the channels that allready exists The Battery Association suggests that the batteries should be collected as close to the consumers as possible. Experiences from both Denmark and Holland show that this gives the highest collection rate. A few specialized stores, where part of their service is changing batteries, should be given the possibility of having a collectionbox. However we basically do not think that the collection should take place at the stores. We believe that the municipalities and the reycling companies, who already have systems for the handling of garbage, should handle used batteries as well. Exactly how the collection should take place is something we will discuss with the municipalities and the recycling companies. In light of the talks we have had with different parties, we imagine the following initiatives from the municipalities: 1. All citizens should be provided with a number of plastic bags for used batteries. We have looked at different proposals and recommend a bag that is constructed in such a way that it is easy to tie a knot around it so that it will be air tight and water proof. The advantages in such a bag are as follows: 1) The bag prevents moisture. 2) The garbage man can take the bag with him at the same time as he is carrying out the other garbage and throw it into a separate container in the van. The bags are distributed through door-to-door-distribution either through the normal channels or through the garbage man with e.g. ten bags at a time. 2. All private households should be provided with a water proof plastic container that should be placed next to the garbage can. The container is devised in such a way that the consumer can signal that the container is full, sort of like "the vacant sign" we know from the doctor. The advantages in using such a container for the bags are as follows: 1) Many different garbage disposal systems exist and it is difficult to make a standard hook so that the bag can hang on the garbage can by itself. 2) A detachable hanging bag could easily fall off and be torne to pieces. 3) A detachable hanging bag could be taken by children and unauthorized persons, thus creating a risk of the children coming near perhaps hazardous batteries. 3. In apartment houses big containers are placed in the garbage rooms like those placed in Frederiksberg where the tenants can place the bags. The containers are emptied by the garbage man or in certain municipalities by the special environmental car. 4. The door-to-door-collection is supplemented by other initiatives depending on the municipalities' ingenuity e.g. by containers at the refuse dumps and in connection with public bottle and newspaper collection containers, by collection at schools and so forth. The municipal collection stations should work as collection places for the used batteries. From here they should be sent to one of the 18 municipal collection stations, exactly like the system works today. By using existing transport and distribution systems, and by avoiding unnecessary production, distribution and emptying of collection containers at other places than where there is already a recycling system, it is ensured that the collection will strain the environment as little as possible. We suggest that the financing should take place through the municipal waste fee (In this paragraph we have modified the economic proposal) Today everybody pays to get rid of their garbage, the households through the municipal waste fee, the public authorities and the companies through payments to a contractor who handles the garbage. Today the municipalities and the companies already use a part of their municipal waste fee to pay different contractors to dispose of used batteries. Thus there already exists a system that finances the disposal of used batteries and we believe that this system should continue. In the original positionpaper we suggested that one should elaborate the systems in order to achieve a high collection rate. We estimate that the national information regarding the collection system, to begin with, can be handled as follows:
In relation to our first proposal we have now removed the cost for the national information because as mentioned we suggest that this instead is included by the suppliers of batteries as part of the marketing of batteries. However we estimate that it will cost more to collect the batteries in the households than we first imagined and therefore we have maintained the original budget:
This corresponds to each household paying kr. 15,00 + value added tax per year through the municipal waste fee while the companies should share the payment of kr. 5.200.000,00 + value added tax per year. It would be inexpedient to establish a system where the financing of the system is funded through a tax on the batteries. If there is to be a tax on the batteries, the fee should be payed by the importers. This would mean that:
Therefore we think that the financiel costs that are connected with enviromentally- friendly processing of batteries should be put on the garbage. It will be:
- and why treat batteries differently than other garbage? Batteries are not reserved the few. It is a householdarticle and the disposal is a part of the normal household garbage. We suggest that the municipalities establish their own collection organization or that a new collection organization is established (this paragraph has been radically altered) It will be necessary to establish a collection organization that can handle a coordinated collection and enter into contract with the companies who are to sort and process the batteries. Alternative 1 As a primary proposal we suggest that a collection organization is established - called The Genbat Foundation - which should be responsible and have the ownership of the used batteries from the moment they leave the municipal collection system, and that the operation of the organization should be covered by the municipal waste fee. In The Genbat Foundation there should be representatives from The Enviromental Protection Agency, the municpalities and the importers of batteries. This proposal requires new legislation that gives the foundation the possibility of using the municipal waste fee. In that connection the Battery Association suggests that Genbat Fonden has the entire responsability regarding the collection of batteries including the administration of the nickel-cadmium system. Since 1996 there has been a profit of more than kr. 100.000.000 which so far has been given to the Treasury. Instead that money could be administrated by The Genbat Foundation who could use the interests for outwards turned activities. When considering that an important reason for collecting all batteries is the desire to collect the nickel-cadmium batteries, an initiative where the interests of the money that is continuously accumulated will benefit the Battery Association is in the spirit of the whole system. Among other things, the organizations tasks will be:
Alternative 2 If it is not possible to get a law passed through, the Battery Association suggests that, as it is now , the municipalities establish a collection organization themselves that can take care of the practical problems. This has also been suggested by the National Association of Local Authorities in Denmark. This organization could be an association such as Sam-Bat or a new organization under the National Association of Local Authorities in Denmark. Regarding sorting and recycling (This section has not been changed) In order to ensure the cheapest form of recycling an effective sorting of the batteries into different types is necessary. The cheapest form of sorting is sorting mechanically. Experiences in Holland have shown that the quicker the batteries get through the collection system the easier it is to sort them mechanically. However it will always be necessary for the battery garbage to be sorted by hand at first, because the mechanical sorting can not handle damaged batteries, large batteries and objects - garbage that invariably will be part of the disposal. In Denmark we have the advantage that the municipal collection stations are high geared to carry out the first sorting by hand and this system can be maintained. When the project is started most of the batteries will be free of heavy metals, and these batteries can be processed by the metals industry. The problem is that probably there will still be a limited amount of batteries that contain heavy metals and these cannot be processed by the metal industry. Therefore they will have to be sent to other facilities. Batteries that can not be efficiently sorted must be looked upon as enviromentally hazardous refuse with special demands for the processing. We believe that there should be effective methods of controling the goals (This paragraph has not been changed) The aim of the collection scheme is to avoid that the batteries end up in the ordinary day to day refuse. In order to measure the success of the project it will be necessary to examine whether the refuse is contaminated with used batteries in the same way that air polution is measured by means of air testing etc. In Holland methods for examining the quantity of batteries in the waste stream have been developed, and these methods must also be the basis of the evaluation of the project's efficiency in Denmark. Several investigations have shown that the consumers keep new as well as used batteries. This means that trying to determine the quantity of disposed batteries on the basis of sales is subject to a high level of uncertainty. Reservations We would like to bring to your attention that all figures in this document are approximate figures that will have to be worked out with more accuracy. The Danish Battery Association, June 25, 2001
Frederik Madsen |
