Guidance

DfT guidance note 26: carriage of small mixed WEEE (SMW) from collection points to intermediate processing facilities

Published 7 July 2017

This guidance solely applies to the national carriage in Great Britain of small mixed waste electrical equipment (WEEE) that has been deposited at designated collection facilities to intermediate processing facilities.

It should be read alongside that issued by the Environment Agency titled “Storage and Treatment of Small Mixed WEEE – Quick Guide 413_14” dated 17 March 2014.

This guidance does not cover the carriage of small mixed WEEE from ‘Bring Banks’ or collected as part of kerbside recycling collection rounds.

1. What constitutes small mixed WEEE?

Small mixed WEEE (SMW) comprises of a wide range of waste electrical items including:

• small household appliances
• IT and communications equipment
• powered tools, toys and sports equipment
• medical devices
• control instruments
• smoke detectors and dispensers

It does not include other WEEE items, which should be separately collected in their own right, such as:

• cathode ray tube and flat-screen televisions and monitors
• refrigeration equipment
• large domestic appliances
• fluorescent lamps

2. Thermal runaway

SMW may contain lithium-ion batteries in an unknown condition. Under certain conditions, these batteries may discharge their stored electrical energy in an event known as a thermal runaway, which may lead to the outbreak of a fire.

In order to mitigate this risk, it’s important that as many lithium-ion batteries are removed from this waste stream as is practical, especially those that are more powerful.

For SMW deposited at designated collection facilities, this can be achieved by site operators using signage to encourage members of the public to separate batteries from this waste stream and to put loose batteries and battery packs in dedicated receptacles. Staff at these collection sites should be trained in the appropriate segregation of waste, including SMW and be vigilant for the presence of batteries, removing them where practical and safe to do so. It’s reasonable to expect that collection sites for SMW of business origin will achieve a high level of separation of batteries through signage and training.

3. Weight of SMW

Studies funded by DEFRA show that about 0.06% by weight of SMW being carried from designated collection facilities to intermediate processing facilities is comprised of batteries of all types, not just lithium-ion batteries. Even assuming a worst-case scenario that all batteries are lithium-ion batteries a typical 2-tonne load of SMW will contain about 1.2kg of lithium-ion battery. An average laptop battery weighs 270g, so a worse-case load of 2 tonnes might contain about 4 such batteries or 6 in a 3-tonne load.

4. How to report fires

Over many years of operational experience across Great Britain, there have been no reports of fires occurring during the bulk carriage of SMW that can be attributed to the presence of lithium-ion batteries. Any fires during the carriage this waste that can be attributed to the presence of lithium-ion batteries should be reported by waste contractors to [email protected].

5. Future of this guidance

Given the composition of lithium-ion batteries in SMW and the current safety record, the Department for Transport, as the competent authority for the carriage of dangerous goods by road in Great Britain, is content to issue this national guidance.

However, to account for the changing composition of this waste stream, before 31 December 2021 a further assessment of the percentage by weight of batteries in SMW being carried from municipal collection points to intermediate processing facilities should be carried out by DEFRA.

This guidance will be withdrawn or revised by the Department for Transport if evidence emerges that the risk associated with the carriage of this waste stream is significantly higher than is presently assessed.

6. ADR and special provision 670

The provisions for the carriage of lithium-ion batteries in waste were introduced into the 2005 Edition of the European Agreement on the Carriage of Dangerous Goods by Road known as ADR. The provisions continue to evolve for waste electrical equipment containing lithium-ion batteries and the 2019 Edition is expected to introduce a new special provision 670:

“670 (a) Lithium cells or batteries installed in equipment from private households collected and handed over for carriage for depollution, dismantling, recycling or disposal are not subject to the other provisions of RID/ADR/ADN including special provision 376 and paragraph 2.2.9.1.7 when:

• They are not the main power source for the operation of the equipment in which they are contained;
• Equipment in which they are contained does not contain any other lithium cell or battery used as the main power source; and –
• They are afforded protection by the equipment in which they are contained.

Examples for cells and batteries covered by this paragraph are button cells used for data integrity in household appliances (like refrigerators, washing machines, dishwashers) or in other electrical or electronic equipment.

(b) Up to the intermediate processing facility lithium cells and batteries contained in equipment from private households not meeting the requirements of (a) collected and handed over for carriage for depollution, dismantling, recycling or disposal are not subject to the other provisions of RID/ADR/ADN including special provision 376 and paragraph 2.2.9.1.7 if they meet the following conditions:

• (i) They are packed in accordance with packing instruction P 909 of 4.1.4.1 except for the additional requirements 1 and 2; or they are packed in strong outer packagings, e.g. specially designed collection receptacles, which meet the following requirements:

  • The packagings shall be constructed of suitable material and be of adequate strength and design in relation to the packaging capacity and its intended use. The packagings need not meet the requirements of 4.1.1.3;
  • Appropriate measures shall be taken to minimize the damage of the equipment when filling and handling the packaging, e.g. use of rubber mats; and –
  • The packagings shall be constructed and closed so as to prevent any loss of contents during carriage, e.g. by lids, strong inner liners, covers for transport. Openings designed for filling are acceptable if they are constructed as so to prevent loss of content.
• (ii) A quality assurance system is in place to ensure that the total amount of lithium cells or batteries per transport unit does not exceed 333kg; NOTE: The total quantity of lithium cells and batteries in the equipment from private households may be assessed by means of a statistical method included in the quality assurance system. A copy of the quality assurance records shall be made available to the competent authority upon request.
• (iii) Packages are marked “LITHIUM BATTERIES FOR DISPOSAL” or “LITHIUM BATTERIES FOR RECYCLING” as appropriate. If equipment containing lithium cells or batteries is carried unpackaged or on pallets in accordance with packing instruction P 909 (3) of 4.1.4.1, this mark may alternatively be affixed to the external surface of the wagons/vehicles or containers. NOTE: “Equipment from private households” means equipment which comes from private households and equipment which comes from commercial, industrial, institutional and other sources which, because of its nature and quantity, is similar to that from private households. Equipment likely to be used by both private households and users other than private households shall, in any event, be considered to be equipment from private households.”

7. Purpose of this guidance

The main purpose of this guidance is to provide an interpretation of special provision 670 (b) (i) regarding strong outer packaging for carriage in Great Britain. Typical SMW containing the order of up to 0.06% by weight of lithium-ion batteries may be loaded into metal skips or other suitable containers used at designated collection facilities.

Such loading must be done in accordance with best practice described in the Environment Agency’s Quick Guide 413_14 so that the SMW remains whole and intact to facilitate the identification and subsequent treatment of components.

Also, in accordance with the Quick Guide, “limited light squashing” of the load is acceptable provided that appropriate measures are taken to ensure that it does not hinder the subsequent treatment of SMW.

8. Prevention of loss of content during carriage

In order to prevent the loss of content during carriage the container should be netted, sheeted or closed, or loaded into a closed vehicle.

9. Packaging marks or signage

The external surface of the container shall be marked “MAY CONTAIN SOME LITHIUM BATTERIES FOR DISPOSAL” or “MAY CONTAIN SOME LITHIUM BATTERIES FOR RECYCLING”. Where it’s judged that such marks are impractical to attach or are likely to become detached or illegible, a sign may be displayed in the driver’s cab, rather than on the surface of the container.

10. Further advice

If there is reason to suppose that a load of SMW is not typical and may contain a significantly higher percentage by weight of lithium-ion batteries, please contact [email protected] for further advice.

Examples of atypical loads include loads containing significantly higher proportions of mobile phones, laptops, tablets or power tools and loads where there is no assurance that batteries have been separated.