The management of waste batteries is a critical environmental issue, given the hazardous substances they contain and the potential for pollution if not handled correctly.
In the UK, the Environment Agency (EA) and devolved administrations are seeking to strengthen regulatory controls through the introduction of new “appropriate measures” for facilities permitted to treat, store, or recycle waste batteries.
An open consultation has been launched to gather views from stakeholders on the proposed measures, which aim to ensure high standards of environmental protection and operational safety.
The consultation closes on 8th September 2025, 11:59pm.
Regulatory context
Waste batteries are regulated under the Environmental Permitting (England and Wales) Regulations 2016 and equivalent legislation in Scotland and Northern Ireland.
Facilities that handle waste batteries must obtain an environmental permit and comply with conditions designed to prevent pollution and protect human health.
The EA periodically issues sector-specific guidance on “appropriate measures” – the standards and practices expected of permitted facilities. These measures are intended to reflect best available techniques (BAT) and ensure compliance with legal obligations.
Rationale for the consultation
Recent incidents, technological developments, and the increasing volume and diversity of waste batteries (including lithium-ion batteries from electric vehicles and consumer electronics) have highlighted the need to update and clarify regulatory expectations.
The consultation seeks to address gaps in current guidance and to harmonise standards across the sector.
Scope of the consultation
The consultation invites views on draft guidance that sets out the appropriate measures for permitted facilities managing waste batteries. The measures cover all types of batteries, including:
- Portable batteries (e.g., AA, AAA, button cells)
- Industrial batteries (e.g., those used in backup power supplies)
- Automotive batteries (e.g., lead-acid car batteries)
- Lithium-ion batteries (including those from electric vehicles and e-bikes)
The guidance is intended for operators of waste treatment, storage, and recycling facilities, as well as regulators, industry bodies, and other stakeholders.
Summary of the draft guidance
The following summary distils the principal “appropriate measures” outlined in the Environment Agency’s June 2025 consultation draft for facilities permitted to treat or transfer waste batteries. The measures are grouped as in the guidance and reflect the standards expected for compliance with environmental permits.
General management
- Management system: Facilities must operate under a documented, up-to-date management system, including environmental policy, staff structure, training, emergency preparedness, and regular review.
- Staff competence: All staff must be adequately trained and competent, with technical managers holding relevant qualifications.
- Accident management: A comprehensive accident management plan is required, identifying risks (including fire and chemical hazards), with clear roles, emergency procedures, and regular drills.
- Accident prevention: Measures include segregation of incompatible wastes, containment of process and firefighting waters, robust site security, and fire prevention (including fire detection/suppression and separation distances).
- Contingency planning: Facilities must have plans for operational disruptions, including alternative waste management routes and procedures for plant malfunctions.
- Decommissioning: Plans must be in place to ensure pollution-free decommissioning and site restoration.
Waste pre-acceptance, acceptance, and tracking
- Pre-acceptance: Operators must obtain detailed information about waste before arrival (type, chemistry, condition, packaging, hazards) to assess suitability and risks.
- Acceptance: On arrival, waste must be checked against pre-acceptance information, weighed, visually inspected, and non-conforming waste must be quarantined or rejected.
- Tracking: An electronic system must record all waste movements, storage, treatment, and dispatch, including inventory and storage durations.
Waste storage and handling
- General storage: Waste must be stored securely, within permitted capacities, with clear labelling, separation distances, and under cover where necessary. Storage durations are limited (e.g., 6–12 months depending on battery type).
- Handling: Waste must be handled to prevent damage, leaks, or fire risk. Daily inspections and prompt management of leaks/spills are required.
- Additional battery-specific measures: Batteries of different chemistries must be segregated. Storage containers must be non-conductive, leak-proof, and chemically resistant. Lithium and lead-acid batteries require rigid, lidded containers; terminals must be insulated. Storage areas must be cool, dry, well-ventilated, and protected from heat/ignition sources. Damaged batteries must be isolated, risk-assessed, and stored in fire-resistant containers.
Waste treatment
- Preparation for reuse: Sorting, testing, charging/discharging, and dismantling must occur in dedicated, ventilated areas by trained staff. Large battery packs should be safely discharged before further treatment.
- General treatment: Mechanical treatment must be enclosed, with emissions abatement. Outputs must be fully characterised, and hazardous fractions managed appropriately.
- Battery-specific treatment: Processes must be designed for the battery type/chemistry, with measures to control fire, explosion, and chemical hazards. Electrolyte and hazardous fractions must be safely collected and contained.
- POPs and BFRs: Batteries or fractions containing persistent organic pollutants (POPs) or brominated flame retardants (BFRs) must be identified, segregated, and treated to destroy or irreversibly transform POPs (typically by incineration).
Emissions control
- Point source emissions to air: All process emissions must be collected and abated before release. Emissions inventories and risk assessments are required.
- Fugitive emissions: Measures to prevent dust, odour, and volatile emissions include enclosed storage/treatment, negative pressure, and abatement systems.
- Noise and vibration: Facility layout and operational controls must minimise noise/vibration, with management plans where necessary.
- Emissions to water/sewer: All discharges must comply with permit conditions, with appropriate treatment and monitoring. POPs must not be released to water.
Emissions monitoring and limits
- Air monitoring: Regular monitoring of dust, VOCs, metals, dioxins, and other pollutants, with specified emission limits and frequencies.
- Water monitoring: Monitoring of TOC, COD, suspended solids, metals, and specific hazardous substances, with defined limits and frequencies.
- Records: Emissions inventories must be maintained, and monitoring must use accredited methods.
Process efficiency (Installations only)
- Energy efficiency: Facilities must have an energy efficiency plan, monitor energy use, and implement improvement measures.
- Raw materials: Use of less hazardous or waste-derived materials should be prioritised.
- Water use: Water consumption must be optimised, with regular audits and plans for reduction and reuse.
- Waste minimisation: A residues management plan must minimise waste generation and maximise recovery/recycling.
The draft guidance sets out a comprehensive suite of technical, operational, and management measures for permitted waste battery facilities.
These measures are designed to ensure environmental protection, operational safety, and compliance with legal requirements.
If adopted, operators will be expected to assess and implement these measures, adapting them to site-specific circumstances and maintaining robust records and procedures.
Implications for permitted facilities
If adopted, the new appropriate measures will form part of the regulatory baseline for permitted facilities.
Operators will be expected to review their operations and, where necessary, upgrade procedures, infrastructure, and training to meet the new standards.
Appropriate measures are the standards that operators should meet to comply with their environmental permit requirements.
Failure to comply may result in enforcement action, including variation, suspension, or revocation of permits.
How to respond to the consultation
Stakeholders are invited to submit responses via the Environment Agency’s consultation portal or by email. Click here to read more about the consultation.
Stakeholder engagement is essential to ensure that the final guidance is robust, practical, and proportionate.
All interested parties are encouraged to review the proposals and contribute their views.
If you would like more information about the consultation or legal support with the impact that changes to these measures will have, please speak with James Edes today.