Waste Batteries and Lithium: UK Storage and Carriage

Batteries are now in more of what we throw away than ever: power tools, vapes, e-bikes, mobility scooters, handheld scanners, alarm panels, toys, speakers and vehicles. For waste businesses, that means batteries arrive in loads where nobody expected them, and a damaged lithium cell in the wrong place can start a fire in a skip, a lorry or a transfer station.

This guide covers how waste batteries are classified and coded, how to store and carry them, which paperwork applies and where the main legal duties sit. It is written for small waste carriers, skip firms and trades, and for England and Wales in particular. Rules for hazardous waste and dangerous goods are detailed, so use this as a map and check the current gov.uk and regulator guidance for specifics.

Which regulations apply

Several overlapping sets of rules touch waste batteries:

• The Waste Batteries and Accumulators Regulations 2009. These place duties on battery producers (those who place batteries on the UK market), distributors (shops and online sellers who supply them) and treatment operators. They cover producer registration, take-back, treatment and recycling targets and reporting. Most small waste firms are not producers, but may be treated as collectors or handlers.
• The duty of care and the waste transfer or consignment note rules. The same section 34 duty of care applies to waste batteries as to any other waste, and where a battery is a hazardous waste the Hazardous Waste Regulations require a consignment note.
• Dangerous goods transport rules. Batteries, and lithium batteries in particular, are dangerous goods. In Great Britain the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 bring in the international ADR agreement for road transport.
• Health and safety and fire safety law. The Health and Safety at Work etc. Act 1974 and the Regulatory Reform (Fire Safety) Order 2005 apply to how you store and handle batteries at your premises.
• The WEEE Regulations. Where the battery is inside a product, such as a power tool, a vape or an e-bike, the product is electrical waste. See our guide to WEEE for businesses.

Northern Ireland has its own version of the battery regulations, and Scotland's rules are enforced by SEPA. Check the regulator for your area.

Classification and EWC codes

Waste batteries are mainly found in chapter 16 (waste not otherwise specified in the list) and chapter 20 (municipal wastes, including separately collected fractions). The codes you are likely to meet are:

Lithium-ion and lithium metal batteries are normally coded under 16 06 05 or 20 01 34, depending on where they were collected. The codes themselves are non-hazardous entries, but that does not settle how a particular load is treated. The government's technical guidance on waste classification (WM3) expects you to consider the properties of the waste, and lithium cells that are damaged, swollen or likely to short circuit raise real fire and reactivity risks. Many operators and receiving sites handle lithium batteries as hazardous in practice, and some will not accept them at all unless pre-arranged. Ask your receiving site what it expects before you start collecting.

Mixed loads of unsorted batteries are the common problem. If you cannot tell the chemistries apart, and the load may contain lead, nickel-cadmium or mercury cells, the hazardous entry 20 01 33* applies. Our guide to EWC codes explains how to read the asterisk and how mirror entries work.

Why lithium batteries are a different problem

Lead-acid batteries are heavy, contain acid and need careful handling, but the risks are well understood. Lithium batteries add a fire risk. If a lithium cell is damaged, short circuited, crushed or overheated, it can go into thermal runaway: a fast, self-sustaining reaction that produces heat and flame, can reignite after being put out and is hard to extinguish. Fire services and waste regulators have repeatedly warned that batteries in the wrong waste stream are a cause of fires at waste sites and in collection vehicles.

The practical lesson for a skip or collection firm is that a lithium battery in a mixed skip, a compactor or a pile of general waste is a hazard to your driver, your vehicle and the next site that handles the load. Compacting is the worst case, because it can crush a battery that was intact when it was thrown away.

Items that often contain lithium batteries and turn up in unexpected places include:

• disposable and rechargeable vapes
• cordless power tools and garden tools
• e-bikes, e-scooters and their batteries
• laptops, tablets, phones and power banks
• smoke alarms and some security equipment
• greetings cards and toys with sound modules

Storing waste batteries safely

Good storage reduces both fire risk and the chance of a classification problem later. A sensible baseline, to be adapted to your own fire risk assessment:

• Segregate by chemistry. Keep lead-acid, alkaline and lithium batteries in separate, labelled containers.
• Protect the terminals. Tape over terminals on loose batteries, or bag them individually, so they cannot touch metal or each other.
• Use suitable containers. Use non-conductive, rigid containers with lids. For lithium, use containers designed for the purpose, with an absorbent or non-combustible filler such as vermiculite where the manufacturer or your adviser recommends it.
• Isolate damaged or swollen batteries. A damaged cell should be separated at once, in its own container, away from other waste and from buildings, and flagged to the receiving site.
• Keep them away from combustibles. Do not store batteries next to cardboard, timber, oils or waste that could feed a fire. Keep the area dry and out of direct sun.
• Do not stockpile. Arrange regular collections and avoid holding more than you need. Storage limits and permit or exemption conditions may apply to larger quantities, so check them.
• Think about detection and response. Smoke or heat detection, a clear fire plan and trained staff matter more than the container you buy.

Your insurer may have its own requirements for storing lithium batteries. It is worth asking them before you start.

Carrying waste batteries

For anyone carrying waste batteries, two separate legal questions arise: are you authorised to carry the waste, and are you complying with dangerous goods rules?

Waste carrier registration

Carrying waste batteries in the course of a business means you need a waste carrier registration, the same as for any other controlled waste. If you carry hazardous waste, make sure your registration and your arrangements allow for that. Our guide to waste carrier registration explains the basics.

Dangerous goods rules

Lithium batteries are classified as dangerous goods for transport, with UN numbers that include UN 3480 (lithium-ion), UN 3481 (lithium-ion packed with or contained in equipment), UN 3090 (lithium metal) and UN 3091 (lithium metal packed with or contained in equipment). Waste lithium batteries collected for disposal or recycling are covered by a special provision in ADR, and damaged or defective batteries are subject to stricter packing and carriage requirements. Depending on the quantity you carry and the exemptions available to you, you may need to meet requirements for packaging, marking, documentation, vehicle equipment and driver training, and you may need a dangerous goods safety adviser.

The detail is technical and depends on the quantity and type of battery. If you carry batteries regularly, take advice from a DGSA or your trade body and check the Health and Safety Executive and Department for Transport guidance. Do not assume that because a battery is small it is exempt.

The paperwork

The paperwork follows the classification. For non-hazardous batteries, a waste transfer note with the code, a clear description (type, source, quantity and container) and the transferor and transferee details is the starting point. For hazardous batteries (lead, Ni-Cd, mercury, mixed unsorted batteries and, where you or your receiving site classify them that way, lithium batteries), a consignment note is required, with the hazardous code, the hazard properties and the consignee's permit details. Our article comparing waste transfer notes and consignment notes shows what each must contain.

On a note, describe the load in a way that tells the next person what they are handling. "Waste batteries" is not enough. "Mixed portable batteries from electrical retailer, alkaline and lithium, sorted into separate drums" is better. If lithium cells are present, say so. If the load includes damaged cells, say that too, because the next person needs it for their own safety.

If you are making a non-hazardous note, you can create one at qwtn.co.uk/notes/new. For hazardous batteries you will need a consignment note under the Hazardous Waste Regulations; your receiving site can usually advise on how it wants them completed.

Producers, retailers and what customers should do

Many customers think they can put a battery in the bin. They cannot, and businesses cannot either. Batteries from business premises are the business's waste, and they should go to a registered carrier or a permitted site, not into general waste. Retailers and online sellers who supply batteries above a certain quantity have a duty to offer take-back for waste portable batteries. Producers must register with the appropriate scheme and fund collection and recycling. Businesses that supply or sell batteries should check the thresholds and obligations under the 2009 Regulations on gov.uk and speak to a compliance scheme.

For the customers of a waste carrier, the useful advice is short: keep batteries out of skips and bins, take them to a battery collection point at a retailer or council recycling centre, or arrange a separate collection, and report damaged batteries to the carrier before the day.

A practical checklist for small waste firms

1. Ask about batteries at booking, particularly for house clearances, workshops, offices and retail units.
2. Put batteries on your banned-items list for skips and general collections.
3. Train drivers to spot batteries and to separate them safely.
4. Provide proper containers for collection and keep terminals protected.
5. Check your receiving site accepts the chemistry and quantity you are bringing.
6. Use the right note for the classification, with a specific description.
7. Check your carrier registration and dangerous goods position, and your insurance.
8. Keep photos and records of how the batteries were separated and handed over.