FEAD initial input on the deposit-return systems for batteries

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the initial work of Oeko-Institut and Ramboll on the feasibility and potential benefits of deposit-return systems for batteries under Article 63 of the Batteries Regulation. The consultants’ first workshop correctly identified many of the key issues that must be addressed in the implementation of a battery DRS: legacy batteries, embedded batteries in WEEE, fraud risks, e-commerce freeriding, and complementarity with existing collection systems.

FEAD supports the establishment of a financial return incentive for batteries where it demonstrably prevents fires, improves separate collection and keeps critical raw materials in the European circular economy. FEAD’s preferred model is an EU-mandated, nationally implemented, industry-based deposit refund system, organised in collaboration with existing producer responsibility structures and designed to complement existing battery and WEEE collection networks. The EU should set harmonised minimum requirements, while Member States should implement the system through national structures adapted to their collection infrastructure, costs and PRO arrangements.

FEAD’s preferred DRS model would be based on the following features:

1. Batteries in scope: portable and LMT batteries, including embedded batteries in WEEE. While ideally, the system could prioritise lithium-based and other high-risk batteries, consumers cannot be expected to distinguish battery chemistries, and therefore all battery chemistries should be included in the scope. SLI, EV and large industrial batteries should not be the initial focus of a DRS because they already follow different collection and economic logics.
2. Day-one acceptance of legacy batteries: old batteries and battery-containing products already in households must be eligible for a return incentive from the start, even if no deposit was paid when they were purchased. A DRS limited only to newly marked batteries would not address the current fire problem for many years.
3. Traceability and anti-fraud safeguards: DRS-covered batteries and products should be marked and digitally traceable, with one deposit entitlement per unit, and specific safeguards should be implemented for unmarked legacy batteries. Controls against deposit tourism, and specific rules for online sales and marketplaces must be implemented.
4. Industry-based clearing supported by existing EPR structures: the clearing body should be linked to compliant producer responsibility schemes, with clear coordination with battery PROs and WEEE PROs.
5. Dense and safe return network: retailers, civic amenity sites, municipal collection points, WEEE collection points, repair networks and other authorised collection points should participate in the system. Existing collection networks must not be disrupted.
6. Environmental levy as an alternative option: FEAD recommends that the Commission consider a levy-based return incentive, whereby a charge applied to new batteries or battery-containing products would finance rewards for the return of waste batteries, as another possible option to a strict DRS.

Battery DRS must be assessed primarily as a fire-prevention tool

Battery fires are now one of the most serious operational risks facing the European waste management sector. Lithium batteries and battery-containing products are increasingly found in residual waste, packaging waste, paper/cardboard streams or WEEE. When crushed, compacted, shredded or otherwise mechanically stressed, these batteries can ignite and trigger thermal runaway.

The evidence gathered by the waste management sector shows that this is already a Europe-wide problem[1]:

• In France, fires in waste treatment facilities linked to lithium batteries doubled between 2019 and 2023.
• In Austria, 180 to 240 fires per year in waste facilities are estimated to be caused by batteries.
• In Germany, up to 30 fire incidents per day occur in waste collection vehicles and waste treatment facilities, with around 80% attributed to lithium batteries.
• In the UK, more than 1,200 battery-related fires were reported in refuse collection vehicles and waste sites in 2023, a 71% increase from 2022.

These fires occur throughout the waste value chain, not only in battery or WEEE treatment facilities. They affect collection vehicles, transfer stations, sorting centres, recycling operations and residual waste treatment. Misplaced batteries are difficult to detect in a waste stream, and even well-equipped facilities struggle when high-energy batteries are mixed with dry and highly flammable materials such as paper, plastics or textile.

The economic consequences are severe. Fire incidents in WEEE treatment facilities have been estimated to cost between EUR 190,000 and EUR 1.3 million per incident, and the Irish Waste Management Association estimates that fires caused by batteries in bin lorries or at recycling centres in Ireland cost its members €50m last year[2]. In addition, fire-prevention equipment can account for up to 20% of the total cost of new construction projects. Waste operators are also facing higher insurance premiums, refusal of coverage or loss of insurability.

Recent residual waste sorting data further illustrate the trend. An Austrian sorting campaign[3] has shown that the share of batteries in residual waste increased from 0.05% by weight in 2016 to 0.09% in 2025/2026, while lithium-based batteries increased from 0.002% to 0.013%. On a unit basis, the number of batteries found increased from 20 units per tonne to more than 48 units per tonne, while lithium-based batteries increased from 2 units per tonne to more than 8 units per tonne. In one residual waste truck carrying 8.5 tonnes, 252 batteries were found, including 28 lithium-based batteries.

Similarly, a live AI/X-ray trial in a lightweight packaging sorting plant handling around 20 tonnes/hour detected 70 potentially hazardous elements in 45 minutes, equivalent to around 4.7 hazardous items per tonne, or one item every 38 seconds. The items included loose battery cells and battery-containing consumer products such as earbuds, electronic toys, toothbrushes, game controllers, razors and other small devices.

This confirms a key point for the Article 63 assessment: battery fire risk is unit-based, not tonnage-based. Even very small quantities of batteries in mixed waste streams can create disproportionate operational and safety risks. A DRS should therefore be assessed by its ability to reduce the number of misplaced batteries and battery-containing products, not only by the additional tonnes collected through battery schemes.

Collection gaps remain significant despite existing systems

FEAD recognises that Member States already have battery collection systems in place, funded and organised by EPR schemes, and based on retailer take-back and municipal collection points. These systems must be preserved and strengthened. However, the available data show that they are not sufficient to prevent a significant share of batteries from entering wrong waste streams.

A French ADEME study[4], carried out in anticipation of Article 69 requirements under the Batteries Regulation, estimates that 7,575 tonnes of portable batteries are misplaced in French municipal waste flows (including in recyclable waste, in mixed municipal waste and in recycling centres). The quantity of portable batteries found in municipal waste corresponds to 20.4% of the average portable batteries placed on the French market in 2022-2024.

At EU level, Eurostat notes that in 2022[5], 244 kt of portable batteries were placed on the EU market, while only 111 kt were collected for recycling, corresponding to a 46% collection rate. The Batteries Regulation now requires collection rates of 63% by 2027 and 73% by 2030 for portable batteries. Many Member States remain way below the future portable battery collection target, and this should not be solved by a mere change in the way collection targets are calculated (as foreseen in Article 59 and 60), but by a real stepping-up of the collection systems.

A financial return incentive is therefore needed not because existing systems should be replaced, but because they must be reinforced with a behavioural trigger that consumers understand.

Priority scope: portable and LMT batteries, with risk-based prioritisation

FEAD recommends that the DRS / return-incentive system cover portable and LMT batteries, including batteries embedded in EEE. This is the most coherent scope for consumer-facing communication, collection-target delivery and fire-risk prevention.

Within this scope, the system should prioritise lithium-based and other high-risk batteries through differentiated incentive levels, safety requirements and phasing. This is important because lithium-based batteries are currently the main driver of fire risk in waste management. However, consumers cannot reasonably be expected to distinguish between the different battery chemistries. A chemistry-only consumer-facing system would create confusion and reduce participation. The preferred approach is therefore:

A DRS that excludes embedded batteries would miss a large part of the fire problem, as consumers often dispose of battery-containing products in general waste or wrong recycling streams without being aware of the battery or the associated risks. Where batteries are not readily removable by end-users, they remain embedded when the product is discarded and are more likely to be mis-sorted. The scope of the DRS system should therefore cover embedded batteries and relevant small WEEE, and reward consumers for returning the complete product where the battery is embedded or not safely removable in order to avoid incentives for unsafe dismantling.

Overall, this approach preserves a simple consumer message: return batteries and battery-containing products to authorised collection points – never place them in residual waste or recyclables.

Day-one acceptance of legacy batteries

Any future DRS systems must tackle the question of the legacy batteries. FEAD does not support a DRS design that only reimburses batteries newly placed on the market after the system starts. Such a model would leave old batteries in drawers, garages, offices and WEEE flows for many years, and it would fail to address the current fire risk faced by waste operators.

The need for legacy acceptance is reinforced by the practice of ‘hoarding’, e.g. when consumers delay discarding old, broken, or obsolete electronics and batteries. A Luxembourg study on the practice of hoarding has shown that 72% of citizens were keeping some WEEE at home, and around half of these citizens answered that these WEEE most probably still contained batteries[6]. Meanwhile, a study in Austria[7] estimates that the average household has 21 lithium batteries, showing how hoarding can prevent the collection targets from being met.

The Feldbach pilot incentive scheme for large lithium-ion batteries in Austria is relevant in this context. The consultants’ presentation notes that a EUR 10 voucher for returned “fist-sized” lithium-ion or device batteries led to collection volumes four times higher than the previous year and neighbouring municipalities. Looking more in details at this pilot project, a sharp increase was monitored (+32% lithium battery volumes at Feldbach waste collection centre) when switching from a 1:1 to a 0:1 return model – thereby indicating that the system became more effective when moving towards a 0:1 return model[8].

The DRS should therefore include a day-one legacy return mechanism, in which:

• Consumers can return old in-scope batteries or battery-containing products even if no deposit was originally paid.
• Consumers buying a new battery or battery-containing product can return an old equivalent item and offset the deposit charge.
• The legacy incentive may be lower than the future full deposit where necessary to preserve financial balance and reduce fraud.
• Incentives should be differentiated by risk, size, capacity or product category.
• The system of incentive for legacy batteries should be periodically reviewed to ensure adequacy of its design and economical balance of the system.  

This approach corresponds most closely to the consultants’ option 2c of 0:1 return. FEAD considers that the consultants’ option 2a ‘same battery’ would not be sufficient as it would delay the benefits of DRS until DRS-covered batteries reach end of life.

Legacy batteries incentives should be financed through the deposits on new in-scope batteries (including unredeemed deposits once available), and, where needed, EPR-backed transition funding. The clearing system must maintain sufficient reserves so that paying legacy incentives early does not create unfunded liabilities for future deposit refunds.

Traceability, fraud prevention and deposit tourism

Traceability is a condition for any credible DRS system. FEAD recognises that fraud risks are real, especially if incentive levels are high. However, these risks are manageable if the system is designed correctly from the beginning.

Every producer, importer, distance seller and online marketplace trader placing in-scope batteries or battery-containing products on the EU market should be registered within a compliant battery DRS system – which could be linked to the EPR register. Online marketplaces should be required to verify registration and DRS compliance before allowing batteries or battery-containing products to be sold on their platform.

For new batteries falling under the scope, the DRS should be based on durable identification of the battery. Depending on the category, this could include DRS logo and category marking, serial number or batch identifier or battery passport data for LMT batteries where available. Such traceability aims at ensuring that each deposit or return entitlement should be registered only once. When the battery or product is returned, the entitlement should be cancelled in the clearing system.

Per definition, legacy batteries don’t carry DRS markings. Legacy acceptance is necessary, but it must not become a loophole for importing waste batteries into the system. Legacy batteries should therefore receive a capped or differentiated incentive and be subject to stronger validation:

• Return only at authorised points.
• Digital record of the return event.
• Return limits per person and time period.
• Stricter controls for higher value batteries such as LMT or power-tool batteries.
• Immediate placement in sealed or controlled containers to prevent double redemption.

High-value returns, especially LMT batteries, should not rely on anonymous cash payments. Refunds should be digital, bank-transfer based, voucher-based or linked to a verified consumer account. This reduces fraud, theft incentives and deposit tourism.

Other essential features of a DRS for batteries

Industry-based DRS

FEAD supports an industry-based deposit refund system as it is the most consumer-friendly approach: batteries can be returned to any participating retailer or other collection point. Therefore, financial clearing, reporting, anti-fraud controls and compensation of collection points should be organised at a national level in close coordination with producer responsibility structures – both WEEE and batteries EPR.

At contrary, a purely retailer-based model is not deemed sufficient, including for LMT batteries. Indeed, consumers may no longer know or have access to the original retailer when returning the battery. Retailers may also close, change ownership or stop selling the brand. In addition, these batteries are subject to second-hand markets and cross-border movements, which would render a simple retailer-based model ineffective.

Dense and safe return network

A battery DRS must not weaken the existing collection network. Convenience and network density are decisive for consumer behaviour and ensure success of the DRS. Therefore, retailers, but also existing municipal and civic amenities, WEEE collection networks, offices or any PRO collection routes should be able to be integrated from the start in the DRS.

Retailers remain a key actor in the implementation of the DRS, since point-of-sale return is important. However, physical retailers must not end up bearing the collection and safety costs of products sold by online sellers. E-commerce actors and online marketplaces must be fully integrated into the system and subject to the same financing and registration obligations.

The consultants rightly note that any battery collection system, with or without a DRS, must address fire and safety risks at the collection, storage, transport and handling stages. Therefore, a battery DRS should be based on existing technical safety requirements for battery collection, including for containers, storage areas, damaged batteries, staff training, emergency response and ADR-compliant transport, where relevant.

Finally, in order to avoid disruption of existing collection networks, the DRS should be designed so that free collection remains available even where no deposit or incentive applies.

Incentive level

The incentive should be meaningful enough to influence consumer behaviour, while remaining proportionate and fraud-resistant. The Commission and consultants should model differentiated incentive bands by battery capacity, product category and fire risk. Indicative modelling scenarios could include small incentives for standard portable batteries, medium incentives for Information and Communication Technology (ICT) devices and power-tool batteries, and higher incentives for LMT batteries.

An alternative: environmental levy on new batteries

As an alternative, FEAD recommends considering the implementation of an environmental levy on the sale of new batteries and battery-containing products. Such a levy would be a charge applied when a battery or battery-containing product is placed on the market, for example at the point of sale. Unlike a strict deposit, the amount paid by the consumer would not have to be reimbursed. Instead, the levy would create a dedicated financial pool that could be used to finance related initiatives, including support to the waste management sector in addressing the risks and challenges linked to battery fires. The system would still reward consumers for returning legacy batteries by allowing them to offset the levy when purchasing a new equivalent battery or battery-containing product.

FEAD understands that the consultants considered an environmental levy outside the strict scope of Article 63. Nevertheless, FEAD considers that such a levy could be assessed as another possible option to a DRS in the upcoming study. The levy could be differentiated by battery size or product category and could offer more flexibility than a strict deposit model, because no fixed amount would have to be returned to the consumer, making it easier to reduce fraud risks. Such an environmental levy should be additional to existing EPR systems and should not relieve PROs of their obligations.

Conclusion

FEAD supports an industry-based battery DRS that is targeted, practical and designed primarily to prevent fires, reduce battery misplacement, increase separate collection and recover critical raw materials. It should be EU-mandated but nationally implemented, in close coordination with existing battery and WEEE EPR structures.

The system should cover portable and LMT batteries, including embedded batteries in EEE, while excluding SLI, EV and large industrial batteries from the initial scope. It should accept legacy batteries from day one, include strong traceability and anti-fraud safeguards, and rely on a dense and safe return network involving retailers, municipalities, civic amenity sites, WEEE collection points, repair networks and other authorised actors.

FEAD calls on the Commission and its consultants to assess this model in the next phase of the study. FEAD also asks that an environmental levy on new batteries and battery-containing products be considered as another possible option to a strict DRS.

[1] https://fead.be/wp-content/uploads/2025/05/Battery-Fires-in-Waste-Management_-Joint-Paper.pdf

[2] https://www.rte.ie/news/ireland/2026/0318/1564004-vapes-return-scheme/

[3] Battery Research on Market, Risk and Fire Statistics (Elena Dvorak, Marlene Korn and Thomas Nigl, May 2026)

[4] https://librairie.ademe.fr/economie-circulaire-et-dechets/9068-evaluation-de-la-part-de-batteries-dans-les-dechets-municipaux-et-dechets-eee.html

[5] Waste statistics – recycling of batteries and accumulators – Statistics Explained – Eurostat

[6] https://download.data.public.lu/resources/waste-and-ressources-electrical-and-electronic-equipment/20250410-140433/ilres-hoarding-decembre2024.pdf

[7] Experts warn of the risk of electrical and battery fire in the coming months – KFV – Kuratorium für Verkehrssicherheit

[8] https://www.voeb.at/service/voeb-blog/detail/show-article/pilotprojekt-zur-digitalen-sammlung-von-alten-lithium-akkus-in-feldbach-erfolgreich-beendet/

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be