Manage waste lead acid batteries containing POPs
Identify, describe, classify, and manage waste lead acid batteries containing persistent organic pollutants (POPs).
Applies to England
This guidance applies to waste automotive, industrial and portable lead acid batteries. It does not apply to other types of waste battery.
The plastic cases of waste lead acid batteries may contain persistent organic pollutants (POPs).
Identify waste lead acid batteries that contain POPs
You can identify if a waste lead acid battery may contain POPs by checking:
- what type of plastic the case is made from
- if bromine is present in the polymer
Where the battery case is made of :
- polypropylene plastic only – it should not contain POPs
- other plastics – for example acrylonitrile butadiene styrene (ABS) - it may contain POPs
You can also use x-ray fluorescence (XRF) to scan the plastic case for bromine, an indicator of the presence of brominated flame retardants including POPs. However, you must:
- have the right training for using XRF and use a suitable device
- contact the Environment Agency to check if you need to make any changes to your permit and management system
- be able to show that your assessment process works and is accurate – the Environment Agency may ask you for this evidence
You are not required to use XRF to scan for bromine.
You can assume that POPs are not present, and the following guidance does not apply to that battery if you can demonstrate that the battery case either:
- is made of only polypropylene plastic, not other polymers
- does not contain bromine at relevant levels
If you do not know the type of plastic the lead acid battery case is made from, and have not scanned it using XRF to identify the presence of bromine, you should assume it contains POPs.
Describe lead acid batteries that contain POPs
In your waste consignment note you must describe waste lead acid batteries that may contain POPs as ‘containing POPs’.
You should list the following additional chemicals in the composition:
- decabromodiphenyl ether
- hexabromodiphenyl ether
- antimony trioxide
You must classify the lead acid battery containing POPs as shown in the following table.
| Lead acid battery type | Waste status | Household | Industrial or commercial |
|---|---|---|---|
| Lead acid battery (automotive) | Hazardous and POPs | 16 06 01* | 16 06 01* |
| Lead acid battery (industrial or portable) | Hazardous and POPs | 20 01 33* | 16 06 01* |
| Lead acid battery (mixed automotive, industrial, and portable) | Hazardous and POPs | Both 20 01 33* and 16 06 01* | 16 06 01* |
(*) An asterisk at the end of the code means the waste is hazardous.
If the lead acid battery does not contain POPs, see the guidance on how to classify different types of waste electronic and electrical equipment.
Dispose of waste lead acid batteries containing POPs
You must destroy the lead acid batteries containing POPs, or the material containing the POPs, by sending them to either:
- an incinerator (D10 or R1 hazardous waste, municipal waste, or cement kiln)
- a metal smelter (R4) to destroy the POPs
The municipal or hazardous waste incinerator, cement kiln, must be authorised to accept POPs waste.
You must not use other waste recovery and disposal activities (including storage, treatment, landfill, or plastic recycling) except as indicated in this guidance.
Sort, store and repackage waste lead acid batteries containing POPs
You may only temporarily store or repackage waste lead acid batteries containing POPs before:
- pre-treatment to separate the POP containing materials for destruction
- destruction of the POPs
You must also sort lead acid batteries with polypropylene cases, that should not contain POPs, from those with other cases.
You must also hold an environmental permit or exemption that allows this activity.
Pre-treatment of the battery to separate the POP containing materials for destruction
You must only treat a waste lead acid battery containing POPs for the purpose of separating the POP containing plastic case materials for destruction.
You must send all fractions from the treatment of the battery that contain POPs containing plastic material for destruction.
The classification of the plastic fraction is changed by the presence of non-plastic (non-conforming) materials.
You should classify a separated plastic fraction that does not contain non-conforming materials as shown in the following table.
| Waste type | Waste status | Household type | Industrial or commercial |
|---|---|---|---|
| POP containing plastic from lead acid batteries | POPs and non- hazardous | Does not apply | 19 12 04 |
You should classify a separated plastic fraction that contains non-conforming materials as shown in the following table.
| Waste type | Waste status | Household type | Industrial or commercial |
|---|---|---|---|
| POP containing plastic from lead acid batteries | POPs and hazardous or non-hazardous | Does not apply | 19 12 11* or 19 12 12 |
(*) An asterisk at the end of a code means the waste is hazardous.
You must check the concentration of hazardous chemicals to determine if the 19 12 11* or 19 12 12 code applies, and if the waste is hazardous or non-hazardous.
Pre-treatment of plastic fractions to separate POP containing polymers for destruction
You must only treat the plastic fraction, from pre-treatment of the battery, by density separation (or equivalent) to reliably separate:
- the heavier POP containing ABS and other plastic
- the lighter unbrominated, polypropylene fraction
You must send the POP containing plastic fraction for destruction and should classify it as shown in the following table.
| Waste type | Waste status | Household type | Industrial or commercial |
|---|---|---|---|
| POP containing lead acid battery plastics from density separation | POPs and hazardous or non-hazardous | Does not apply | 19 12 11* or 19 12 12 |
(*) An asterisk at the end of a code means the waste is hazardous.
You must check the concentration of hazardous chemicals to determine if the 19 12 11* or 19 12 12 code applies, and if the waste is hazardous or non-hazardous. You cannot use 19 12 04 if non-conforming materials are present in the waste.
Once you have reliably removed all the ABS for destruction, you may describe the lighter, unbrominated, polypropylene fraction as follows, and send it for recycling.
| Waste type | Waste status | Household type | Industrial or commercial |
|---|---|---|---|
| Polypropylene from lead acid batteries | Non-POPs and non-hazardous | Does not apply | 19 12 04 |
The density separation process may produce other heavy mixed fractions like fines or sludges. These should be classified as shown in the following table.
| Waste type | Waste status | Household type | Industrial or commercial |
|---|---|---|---|
| POPs containing fines or sludges from the density separation of lead acid batteries plastics | POPs and hazardous or non-hazardous | Does not apply | 19 12 11* or 19 12 12 |
(*) An asterisk at the end of a code means the waste is hazardous.
You must check the concentration of hazardous chemicals to determine if the 19 12 11* or 19 12 12 code applies, and if the waste is hazardous or non-hazardous.
Destruction in a lead smelter
You may destroy plastic containing POPs from waste lead acid batteries in an R4 lead smelter if the lead smelter:
- is permitted to accept that waste
- has successfully shown the reliable destruction of POPs through an appropriate destruction efficiency assessment (you must do this from 1 July 2024)
- monitors for emissions of both chlorinated and brominated dioxins and furans
Any R4 smelter must meet the dioxin and furan emission limit requirements from Annex 5 Part 1 of the POPs regulations.
Operators of lead smelters should contact the Environment Agency for more information.
Export waste lead acid batteries, or wastes from their treatment, containing POPs
Destinations and waste management activities
You must only export the waste for destruction of the POPs. You may include pre-treatment to separate the POPs containing plastics for destruction. See section 3 of this guide ‘dispose of lead acid batteries containing POPs’, for activities that are allowed.
Where POPs will be destroyed, you may include recovery of lead or recycling of plastic that does not contain POPs.
The combination of hazardous waste and POPs severely restricts both destination countries and allowed waste management options.
Lead acid batteries
You must notify the export of lead acid batteries from England to destinations outside the UK. You must apply to the Environment Agency for consent to export the waste.
You must describe lead acid batteries that contain POPs. You must send lead acid batteries with ABS cases:
- for destruction (or irreversible transformation) of the POPs
- at an R1 Facility (typically an incinerator or cement kiln) or R4 smelter
- within the EU or EFTA (European Free Trade Association)
Where an R4 smelter is used to destroy the POPs, you will need to show that the smelter reliably destroys POPs and meets the emission requirements. For more information, see the section ‘destruction in a lead smelter’.
You can only send the lead acid battery for treatment if it is a pre-treatment to separate the POP containing plastics for destruction. That treatment may include density separation of plastics.
Lead acid battery plastics (separated ABS plastics and mixed plastics containing ABS)
You must notify the Environment Agency if you export separated ABS plastics, or mixed plastics containing ABS from lead acid batteries. You must not move these wastes under ‘green list’ controls. You must apply to the Environment Agency to get consent to export the waste.
You must describe the waste as indicated in the sections in this guide on:
- pre-treatment of the battery to separate the POP containing materials for destruction
- pre-treatment of plastic fractions to separate POP containing polymers for destruction
You may send ABS plastics and mixed plastics containing ABS from lead acid batteries for destruction (or irreversible transformation) of the POPs:
- at an R1 facility (typically an incinerator or cement kiln)
- within the EU or EFTA (European Free Trade Association)
You can only send mixed plastics for treatment if that is a pre-treatment to separate the POP containing plastics for destruction. The uncontaminated polypropylene fraction can then be recycled.
Other fractions from the treatment of lead acid batteries containing ABS plastics
This includes lead metal and lead paste fractions containing any quantity of ABS plastics.
You must notify the export and must not move these wastes under ‘green list’ controls.
You must send the POPs for destruction. Where an R4 smelter is used to destroy the POPs, you will need to show that the smelter reliably destroys POPs and meets the Environment Agency’s emission requirements. For more information see the section in this guide ‘destruction in a lead smelter’.
Please contact the Environment Agency if you need more advice, providing a description of the waste and its origin.
Other countries and waste management options
Export to non-OECD countries is prohibited, there are 36 OECD countries.
You may need to prove that destinations in the OECD, outside of the EU and EFTA, operate to comparable R1 and R4 standards and reliably destroy POPs.
Export for disposal is limited to OECD countries that are also EU or EFTA countries. It is prohibited to export to OECD countries that are not EU or EFTA countries for disposal.
Export for recovery is prohibited for POPs waste, with the exception of destructive technologies like incineration with energy recovery or recovery of metals and metal compounds.
See importing and exporting waste for more information on the requirements for international waste shipments.
Import of waste lead acid batteries, or wastes from their treatment, containing POPs
You must notify the imports of lead acid batteries, or wastes from their treatment, containing POPs.
You must manage the waste in line with this guidance, with the exception that disposal operations are normally prohibited.
Existing notifications for export
You should consider:
- the fate of the POP containing plastic
- the description of the waste
You can continue to export lead acid batteries under your existing notification if you can prove the following to the Environment Agency.
- The POPs in the plastic are being destroyed in line with this guidance.
- The description of the waste does not identify the presence of POPs, you have provided that additional information separately to all parties in the export chain.
You must not export under your existing notification if the fate of the plastic containing POPs is uncertain or inconsistent with this guidance.
All notifications received after the date on this letter must identify the presence of POPs and provide details on the fate of the POPs plastics.
Applications for approval as a facility to treat, recycle or export waste batteries for treatment and recycling
You should make the fate of POPs-containing plastic clear in your application.
The Environment Agency’s chemical compliance staff will be reviewing applications for approved battery treatment operator (ABTO) and approved battery exporter (ABE). They may contact you if the fate of the plastic is unclear.
See Waste batteries: treat, recycle and export for information on how to apply.