International Review of Waste Management Policy - Department of ...

26.11 Evasion and Enforcement
The collection system may charge manufacturers who do not belong to the collection
system for the costs of the sorting, recycling or disposal of the sorted batteries (Article
4 Battery Decree).
Infringements of the regulations, for the purposes of Article 61, Para 1, No. 5 of the
German Waste Management and Recycling Act, are deemed to have been committed
by parties who, for example, put batteries on the market contrary to the Battery
Decrees provisions or do not take back batteries.
26.12 Lessons Learned
According to the Battery Directive 2006/66/EC, Member States must reach a
collection quota of 45 % of portable batteries and accumulators put into circulation by
2016. In Germany the increased awareness and participation of consumers in a free
of charge collection system for used batteries has – after a period of about eight
years – led to a total amount of 14,132 tonnes of portable batteries being collected
in 2007, or around 42 % of the amount of portable batteries put on the market.
The widespread and easy accessibility of collection boxes for end of life batteries is a
prerequisite for the participation of consumers in the collection system and avoids
disposal of household batteries into the residual waste stream.
However, the battery decree has no incentives for producers and consumers to shift
the consumption in favour of secondary batteries.
The discussion on the revision of the Battery Decree in Germany covers the following
points:
485
� Producers and importers of Batteries shall register with one central body
before they may put batteries into circulation;
� Adoption of the collection rates of the new Battery Directive for used portable
batteries and accumulators of 25% by 2012 and 45% by 2016;
� Collection and recycling systems run by producers need an authorisation
which should only be granted if concrete collection and recycling targets are
met;
� Extended labelling duty; and
� Marketing prohibition for portable batteries with more than 0.0002% cadmium
per weight.
Key issues for the policy are:
� Avoidance of free riders / all battery producers participate in take-back
systems, like GRS (Gemeinsame Rücknahmesystem Batterien);
� Collection and treatment infrastructure is tailored to the amount of GRS
disposed;
� Consumers need to find the take-back system convenient so they do not
illegally dispose of batteries in the residual waste;
International Review of Waste Policy: Annexes