Whilst the quantity of portable batteries placed on the market (POM) in Quarter Three 2021 at 11,021 tonnes, was the highest reported in quarter three in any year since implementation of the Regulations, the UK looks on track to meet its 2021 obligation. The quantity of portable batteries collected by Battery Compliance Schemes (BCSs) in Quarter Three 2021 was marginally down compared to Quarter Two 2021, however collections were also higher than those that are typically reported in Quarter Three each year.

The portable data published by the Environment Agency on 1^st December 2021 shows:

Based on the above, an additional 1,065t of battery evidence is required to meet the UK 2021 obligation.

Outlook for the 2021 compliance year

The Environment Agency’s estimated 2021 obligation assumes the quantity of batteries POM in Quarter Four 2021 will be equivalent to Quarter Three 2021. In reality, due to the “Christmas spike”, Quarter Three POM volumes are typically 60% to 70% of those in Quarter Four. On this basis, we would expect that over 2,000t of additional battery evidence will be required, which given that BCSs typically collect approximately 4,900t of batteries each quarter, should be comfortably achieved.

A word of caution, as we explained in our last market update, new Agency guidance requires that by default, batteries weighing over 4kg that are not automotive or industrial batteries, are classed as portable batteries unless there is robust evidence to the contrary. This is likely to impact the number of registered portable battery producers and the quantity of portable batteries POM, although the impact of this is currently unclear. Whilst not all producers may yet be aware of the changes or its impact to them, we would expect that some will reclassify industrial batteries as portable batteries in their Quarter Four 2021 data submissions. This would increase the 2021 UK obligation. There may be early signs of this happening in the Quarter Three 2021 data, with the quantity of both lead-acid batteries and cadmium batteries being higher than in the same period in 2019 and 2020, although given the scale of the change, the link is far from clear. Whilst it currently seems unlikely that any increase in POM data due to implementation of the new guidance will prevent 2021 target achievement, it could make the achievement of future targets more difficult. Not only could POM data increase significantly, resulting in higher targets, but also because portable batteries that have been collected to date, but for which evidence has not yet been issued, may need to contribute to the targets earlier than anticipated. Future compliance with target may not therefore be as comfortable as the current data suggests.