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English

The Battery Associations answer to the European Commission

Dear European Commission,

Thank you for the invitation to answer the Commissions presentation regarding a revision of the battery directive.

The Battery Association, consisting of importers and manufactures of batteries in Denmark, has following comments:

Because the aim of a directive is to handle the environment with care, the starting point must be to look at what is best for the environment. This is all very clear, but so far we feel that the discussion has been so confused and that matters without any reason have been made more complicated than they in fact are. Therefore, it is necessary to start with the most important; the environment.

Even though more than 90 % of all batteries are not dangerous to the environment, the Battery Association finds the collection of batteries good for the environment. This is based on the fact that Danish inquries show that is is almost impossible to explain the consumer that only some types of batteries must be collected or that some types must be collected in one way and some in another way.

Firstly, it is important to send one clear message: In order to ensure that all batteries that are dangerous to the environment are collected, all batteries must be collected.

In Denmark we do not have any organized collection of batteries, but the Danish Environmental Protection Agency (EPA) has, based on a future directive, carried out several projects in order to promote the collection of batteries.

In Denmark we use about 77.000.000 batteries per year and 87 % of these are used in the households. In order to obtain a high collection rate it is therefore necessary to make a special effort towards the households.

The Danish EPA has asked the Center of Alternative Social analysis, CASA, to make a study with the purpose of illustrating different ways of involving the consumers in the collection of batteries. 1)

Regarding the proposal of new collection systems, the consumers express a general wish for collection systems near the home. Furthermore the consumers wish for the collection systems to be nationwide, so they do not have to use a different collection system if they for example are at the country or move to another city.

Based on the wish of making the collection system so easy as possible for the consumer, the Battery Association has suggested a system where the consumer places used batteries in a normal waste bag, ties the waste bag and hangs it on the dustbin. Then the garbage collector throws the waste bag in a special bin at the garbage truck and when he reaches the garbage station this bin is emptied.

The garbage company, BOFA, at Bornholm has used this system since the 1st of January 2002 and they have had great success. Nearly all buckets for batteries have been removed from the stores at Bornholm, because no one deliver there batteries there anymore. The system is not only used in single-family houses etc. but also in block of flats where the consumers can hang there used batteries in a bin on the container in the courtyard.

A study made by COWI Consult for the Danish EPA (2) concludes that a temporary rough calculation of the consumption of batteries in the period 1990-1997 shows a consumption of about 410 grams/inhabitant and 540 grams/inhabitant per year.

There are about 21.500 households at Bornholm and about 3.500 summer houses.

In 2001 8.000 kilograms of batteries were collected including trade, and with about 44.000 residents this estimates 182 grams per inhabitant.

In 2002 the collection rate estimated 12.800 kilograms of batteries including trade, which means that the collection at Bornholm in 2002 estimated 290 grams per inhabitant.Of this about 1.680 kilograms of batteries are collected from the trade, which means that about 255 grams of batteries per inhabitant are collected from the private households.

Related to other collection systens investigated by the Danish EPA (2), Bornholm has, in one year, with this new system obtained the highest collection rate per inhabitant in Denmark.

Bornholm is also very close to the goal of collecting 75 % of all batteries - a result obtained in one year.

The success has made other garbage companies use the new system and here the same results appear.

What is the advantages with this system?

The system is easy for the consumer. The message is simpel and easy to communicate. By this a very high collection rate is obtained, and thereby the system is environmentally desirable.
The system is cheap. The garbage company at Bornholm has not had a single extra expence in relation to the fact that the garbage collector takes the batteries in the bin and throws them in a bucket at the truck.

It is all so simple and very easily done. You avoid the difficulty with distributing the buckets in the stores and empty them again, which is also an environmentally strain. No hugh administration of demanding fees for the financing of the collection. No big chronium-plated battery collection organisation to finance.

In order to support the system, the Battery Asssociation has offered the garbage companies, who use ore want to use this system, to support them with information. At Bornholm, the Battery Association provides information materials to all stores who sell batteries. In that way the consumer becomes aware of how the batteries must be delivered after use already when he buys the battery. The Association has also provided about 20.000 labels to all dustbins at Bornholm with information about the system.

The system is based on a fundamental Danish principle; a polluter pays principle. This is a solidary principle which makes all in the battery - chain responsible for the collection of batteries in a environmentally correct way.

In the recent years there has been a tendency to promote the so-called producer liability. The producer liability means that the producer takes care of the waste management of the product and then adds the expences of this waste management to the price of the product. In reality it is therefore the consumer who pays for the producer liability even though the consumer is not responsible for the waste management. This is an illogical and anti-social system which damages the environment in two different ways:

1. It removes the feeling of responsability and commitment from the person who via his consumption creates a garbage product.
2. It builts separate waste management systems with own administration systems, which are a strain to the environment.

In Denmark, the producer liability is mostly promoted by the private garbage companies and their organisations who are interested in getting the assignments passed over to them. The Battery Association thinks that an environmentally damaging special interest like this must give ground to a system who serves the environment and the economie the best.

At the home page of the Danish Battery Association it is possible to see a short film (38 seconds) about how easily the collection system works at Bornholm.

Copenhagen April 28th 2003

BatteriForeningen

Frederik Madsen

Annex: Position paper of 21st of March 2003.

Notes:

1. Center of Alternative Social analysis, CASA: "Pilot project regarding ways of involving citizens in the collection of batteries", made by Lis Husmer, CASA, Ulf Hjelmer, Gallup and Line Holst Jensen, Greenline Consult.

2. Environmental project number 777, 2003. Collectionsystems for batteries. Existing experiences from Denmark and foreign countries made by Charlotte Libak Hansen, COWI and Erik Hansen, Cowi.