Battery Waste codes under the EU List Of Waste, the Basel Convention and the OECD Decision.

Dr. Ir. Alain Vassart

EBRA Secretary General

ICBR 2020 Workshop, 18 September 2020

EBRA is the association of the European battery recycling and sorting industry. We represent the interests of actors involved with sorting, treating and recycling consumer, industrial or automotive spent batteries (apart from lead-acid batteries).

Europe

Principles of the EU waste classification

1. EWL : use the decision tree to find the EWL code

2. Check if the code is:a) Absolutely non hazardous

b) Absolutely hazardous (*)

c) Mirror code (hazardous properties to be determined)

3. Check the POP regulation: certain waste containing POP above certain thresholds are also considered as hazardous

Hazardous waste streams trigger different, more complex and costly duties.

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Decision tree for

EWL code

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STARTDefine origin and external characteristics of the waste

Only packaging?

Find process/origin in chap 1 to 12 or

17 to 20.

Check chap. 13,14, 15, 16

Separate collection from chap. 20?

Code xx.yy.99

Find specific code

Find specific code

Find specific code

EWL code

ENDIf necessary, make distinction between Haz and Non-Haz waste

Find EWL code in chap. 15

Step 1

Step 2

Step 4

Step 5

Step 6

Step 3

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

EU classification of waste batteries (1)

16 06 batteries and accumulators

• 16 06 01* lead batteries

• 16 06 02* Ni-Cd batteries

• 16 06 03* mercury-containing batteries

• 16 06 04 alkaline batteries (except 16 06 03)

• 16 06 05 other batteries and accumulators

• 16 06 06* separately collected electrolyte from batteries and accumulators

For MUNICIPAL WASTES (HOUSEHOLD WASTE AND SIMILAR COMMERCIAL, INDUSTRIAL

AND INSTITUTIONAL WASTES) INCLUDING SEPARATELY COLLECTED FRACTIONS

• 20 01 33* batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and

unsorted batteries and accumulators containing these batteries

• 20 01 34 batteries and accumulators other than those mentioned in 20 01 33

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Blue: non-hazardousRed: hazardous

EU classification of waste EV batteries (2)

Absolutely non-hazardous

• 16 06 04 alkaline batteries (except 16 06 03)

• 16 06 05 other batteries and accumulators

Absolutely hazardous• 16 06 01* lead batteries

• 16 06 02* Ni-Cd batteries

• 16 06 03* mercury-containing batteries

• 16 06 06* separately collected electrolyte from batteries and accumulators

Mirror codes

• 20 01 33* batteries and accumulators included in 16 06 01, 16 06 02 or 16 06 03 and unsorted batteries and accumulators containing these batteries

• 20 01 34 batteries and accumulators other than those mentioned in 20 01 33

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Use of HP properties

Li-Ion Batteries

Waste code under Basel Convention

The Basel Annexes and Lists

• Annexes I & II: The categories of waste to be controlled (Y-characteristics)

• Annex III: List of hazardous characteristics (H-characteristics)

• Annex IV: list of disposal operations (D) or recycling, recovery, … (R )

• Annex VIII

– List A (Amber list- Hazardous waste)

• Annex IX:

– List B (Green list – non-hazardous waste)

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Basel: Green / Amber Lists

Green List Amber List

Non-hazardous waste Hazardous waste for recovery

Bxxxx Ayyyy

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The underlying classification system is based primarily on compositional information and secondly on the type / origin of the waste.

Green waste are waste not posing a likely risk to the environment when shipped for recovery.

Notes1. The definition of ‘recovery’ under Basel is different than in the WFD (Resource recovery, recycling

reclamation direct re-use or alternative uses)2. The hazardousness criteria are not identical

Conclusion: the Basel lists do not match perfectly with the EU Waste Code Catalogue.

Basel Convention and Battery Waste

• No many specific codes for waste batteries as in Europe

• Existing project to amend the list of waste to include more types of batteries

(timing?)

• Look at the composition. A battery can be seen from different compositional

point of views:

– Heavy metals (Hg, Pb, Cd mainly)

– Plastics

– Other battery materials

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Basel classification for batteries

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B1090 Waste batteries conforming to a specification, excluding those made with lead, cadmium or mercury

B1110 Electrical and electronic assemblies:• Electronic assemblies consisting only of metals or alloys • Waste electrical and electronic assemblies or scrap ( 1 ) (including printed circuit boards) not

containing components such as accumulators and other batteries included on list A, mercury-switches, glass from cathode-ray tubes and other activated glass and PCB-capacitors, or not contaminated with Annex I constituents (e.g. cadmium, mercury, lead, polychlorinated biphenyl) or from which these have been removed, to an extent that they do not possess any of the characteristics contained in Annex III (note the related entry on list A, A1180)

• Electrical and electronic assemblies (including printed circuit boards, electronic components and wires) destined direct re- use ( 2 ) and not for recycling or final disposal ( 3 )

B4030 Used single‐use cameras, with batteries not included on list A

List B (Annex IX): non-hazardous waste (simplified procedure)

( 1 ) This entry does not include scrap from electrical power generation. ( 2 ) Re-use can include repair, refurbishment or upgrading, but not major reassembly. ( 3 ) In some countries, these materials destined for direct re-use are not considered wastes.

Basel classification for batteries

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A1160 Waste lead‐acid batteries, whole or crushed

A1170 Unsorted waste batteries excluding mixtures of only list B batteries. Waste batteries not specified on list B containing Annex I constituents to an extent to render them hazardous

A1180 Waste electrical and electronic assemblies or scrap ( 1 ) containing components such as accumulators and other batteries included on list A, mercury-switches, glass from cathode-ray tubes and other activated glass and PCB-capacitors, or contaminated with Annex I constituents (e.g. cadmium, mercury, lead, polychlorinated biphenyl) to an extent that they possess any of the characteristics contained in Annex III (note the related entry on list B, B1110) ( 2 )

(1): This entry does not include scrap assemblies from electric power generation (2): PCBs are at a concentration level of 50 mg/kg or more.

List A (Annex VIII) – Amber List – Procedure with prior consent from all involved authorities

Basel classification for LI-Ion batteries: future steps?

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• The Basel classification is more driven by composition and manufacturing process rather than product• No specific entries for Lithium batteries (the word ‘Lithium’ only appears once in B2040: Lithium-tantalum

and lithium-niobium containing glass scraps)• There is however a proposal under discussion but more linked to a HS (Harmonised System / World

Custom Organisation). Timing uncertain.Basel Convention codes WCO codes

A1160 Waste lead-acid batteries, whole or crushed 8549.11 (waste and scrap of lead-acid accumulators; spent lead-acid accumulators)

A1170

• Unsorted waste batteries excluding mixtures of only list B

batteries.

• Waste batteries not specified on list B containing Annex I

constituents to an extent to render them hazardous

Excluding 8549.14 (unsorted and not containing lead, cadmium or mercury)

8549.12 (other, containing lead, cadmium or mercury); this might be the unsorted batteries,

first bullet point, as well as the sorted batteries, second bullet point

8549.13 (sorted by chemical type and not containing lead, cadmium or mercury) if hazardous

for other reasons than lead cadmium or mercury

8549.19 (other) e.g. sorted on other aspects than chemical type, if hazardous for other

reasons than lead cadmium or mercury

B1090 Waste batteries conforming to a specification, excluding

those made with lead, cadmium or mercury

8549.13 (sorted by chemical type and not containing lead, cadmium or mercury) if non-

hazardous

8549.19 (other) e.g. sorted on other aspects than chemical type, if non- hazardous

? 8549.14 (unsorted and not containing lead, cadmium or mercury). Difficult to classify due to an inconsistency in the Basel Convention list.

OECD Decision

OECD waste code

• See waste codes under Basel Convention

• There are some differences but not discussed in this presentation

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Country-specific classification

Austria

• All waste batteries, whatever their chemistries, are

considered as hazardous in Austria according to

national legislations.

• Austria has informed the EU instances.

• The hazardous classification in Austria is enforced

even for non-hazardous EWL codes.

Consequence: procedure with prior consent for export

of waste

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Other EU Member States classifying LIB as hazardous

• The Netherlands (LIB)

• Germany (2 Länder)for LIB:– Battery removed from WEEE: 16.02.15* hazardous components removed from

discarded equipment

– Battery removed from ELV: 16.01.21* hazardous components other than those mentioned in 16 01 07 to 16 01 11 and 16 01 13 and 16 01 14

• Spain (for Ni-batteries, i.e.: NiMH and LIB)

There is definitely a trend.

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Switzerland

• CH is not part of (EU / EAA)

• EU WSR and EWL are replaced by an equivalent

pieces of legislation (VeVa and AVV)

• Li-Ion batteries are classified as hazardous waste

(code: 16. 06.97 (s))

Consequence: procedure with prior consent for export

of waste

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USA

• EoL batteries are considered as Hazardous waste except NiMH, dry NiCd and

Alkaline batteries)

• For storage: Universal waste classification

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Australia

• Batteries are hazardous waste (1989)

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Battery chemistry Basel Code Waste definition

Li-Ion, Li-metal, NiCd, Household batteries

A1170 Unsorted waste batteries excluding mixtures of only list B batteries. Waste batteries not specified on list B containing Annex I constituents to an extent to render them hazardous

LIB Black Mass A1180 Waste electrical and electronic assemblies or scrap ( 1 ) containing components such as accumulators and other batteries included on list A, mercury-switches, glass from cathode-ray tubes and other activated glass and PCB-capacitors, or contaminated with Annex I constituents (e.g. cadmium, mercury, lead, polychlorinated biphenyl) to an extent that they possess any of the characteristics contained in Annex III (note the related entry on list B, B1110) ( 2 )

(1): This entry does not include scrap assemblies from electric power generation (2): PCBs are at a concentration level of 50 mg/kg or more.

Pb-acid A1160 Waste lead‐acid batteries, whole or crushed

Any questions?

EBRA is the association of the European battery recycling and sorting industry. We represent the interests of actors involved with sorting, treating and recycling all kinds of consumer, industrial or automotive spent batteries (including Li-Ion EV and stationary batteries apart from lead-acid automotive batteries).

• Address: EBRA ivzwArcadis Building, Rue du Marquis 1 Markiesstraat B-1000, Brussels, Belgium

• www.ebra-recycling.org• Contact: Alain Vassart, Secretary General

M: +32 492 97 23 30E: alain.vassart@arcadis.com

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http://www.ebra-recycling.org/mailto:a.vassart@arcadisbelgium.be