A Guide to The Battery Compliance Fee:

The UK’s battery recycling regulations are heading for their most significant overhaul since 2009, and the debate about how to design the new system is one that matters enormously for the long-term health of the UK’s recycling infrastructure. At the centre of that debate is a proposed compliance fee mechanism that, on the surface, looks like a sensible way to incentivise better performance. We think it is the wrong answer to the right question, and it is worth explaining why.

A compliance fee tells schemes what happens when they fail to meet their targets. It does nothing to address why they are failing. That is not a policy. It is a workaround.

Here is something that rarely makes it into mainstream coverage of battery recycling in the UK. The country technically meets its battery recycling targets. On paper, the numbers look reasonable. In practice, those numbers are built almost entirely on the recycling of lead acid batteries, the large, heavy batteries found in vehicles and industrial equipment, rather than on the portable batteries that consumers throw away every day.

Lead acid batteries are heavy, straightforward to recycle and generate strong commercial returns from the recovered lead. They are processed in large volumes by a small number of well-established operators, and the Battery Evidence Notes generated by their recycling are relatively cheap to procure. Compliance schemes, whose job it is to ensure their producer members meet recycling targets, have found that buying lead acid evidence is a considerably more cost-effective route to hitting their annual obligations than investing in the infrastructure needed to collect and recycle portable alkaline or lithium batteries, which are lighter, more dispersed, more expensive to handle and, in the case of lithium, come with genuine safety considerations.

The result is a system where the headline recycling rate looks acceptable but the batteries that consumers actually use every day, the AA batteries in the kitchen drawer, the lithium cells in the vape, the rechargeable pack in the power tool, are not being collected at the rates the regulations were designed to achieve.

The UK technically meets its battery recycling targets. But those numbers are built almost entirely on lead acid batteries from vehicles and industry, not the portable batteries consumers throw away every day. The targets are being met. The problem is not.

It would be wrong to pretend this dynamic has not touched even those schemes with the strongest commitment to portable battery collection. Wastecare operates the UK’s largest battery compliance scheme and has made a deliberate strategic decision to reduce its reliance on lead acid evidence over time. But to remain competitive enough to sustain the scheme, and therefore to sustain the portable battery collections that are the whole purpose of running it, some lead acid evidence has had to be procured. That is not a comfortable admission, but it is an honest one, and it illustrates precisely why the structural problem is so difficult to escape from within the current framework.

Even Wastecare, with the strongest commitment to portable battery collection, has had to procure some lead acid evidence to remain competitive enough to sustain its scheme. If the market’s most committed collector faces this tension, the picture for schemes with no such commitment is considerably more acute.

The government’s proposed update to the battery regulations would introduce modulated fees by battery chemistry. In plain terms, this means schemes would no longer be able to hit their targets by recycling one type of battery to the exclusion of others. They would have obligations matched to the specific battery chemistries their producer members are placing on the market, forcing genuine engagement with the full range of portable battery types including lithium.

That modulation principle is the right direction. It closes the lead acid loophole and creates a direct link between what producers put into the market and what they are responsible for recovering from it. The challenge is that the proposed mechanism for dealing with schemes that fail to meet their modulated targets is a compliance fee, similar in structure to the one that already exists in the WEEE system.

The WEEE compliance fee funds Material Focus, an independent not-for-profit organisation that uses the money to run consumer awareness campaigns and initiatives designed to increase electrical recycling rates. Material Focus received £5.3 million from the WEEE compliance fee in 2025. In that same year, total household WEEE collections increased by 3.61% compared to 2024. That sounds positive until you look at the other side of the equation: the amount of electrical and electronic equipment placed on the UK market grew by 5.51% over the same period. The gap between what is going into the market and what is being recovered is not closing. It is widening, and it is widening despite the compliance fee mechanism operating as designed.

The Battery Recyclers Forum, in correspondence with Defra, has been explicit about the risk of replicating this model for batteries. Graeme Parkin, Director of Net Zero Environmental and Chair of the Battery Recyclers Forum, put it directly: a compliance fee risks embedding the same behaviours at a critical point in the development of the UK battery system, providing an easier route to compliance for producers rather than incentivising the investment required to capture the significant volumes of batteries currently being lost to landfill and energy-from-waste.

Material Focus received £5.3 million from the WEEE compliance fee in 2025. Collections grew by 3.61%. The amount of material placed on the market grew by 5.51%. The gap is widening, not closing, despite the mechanism operating exactly as designed.

The compliance fee, as a mechanism, is essentially a financial penalty for failing to meet a target. It does not address why the target is being missed. In the context of portable battery recycling, the reasons are structural: consumer awareness of battery recycling is low, collection infrastructure is patchy and inconvenient, and the unit economics of collecting and processing small portable batteries, particularly lithium cells, make investment unattractive without a genuine push from the regulatory framework.

What is particularly frustrating about this debate is that increasing portable battery collection through existing routes need not involve significant additional cost. Collection rates at Morrisons have doubled through relatively straightforward changes to their in-store recycling units, making them more visible and more accessible to shoppers. No new infrastructure. No doorstep collections. No complex logistics programme. Just better placement, better visibility, and a modest investment in making the right thing easy to do.

Battery collection rates at Morrisons have doubled through changes to the visibility of in-store recycling units, at only marginal additional cost. No new infrastructure. No doorstep collections. Just making the right thing easy to do.

It would be wrong to discuss this issue without being transparent about where Wastecare stands. As the UK’s largest battery compliance scheme and its largest collector of actual portable batteries, we are not commenting from the outside. We are the largest participant in the system, and we are saying clearly that the proposed mechanism will not work.

Throughout this process, and at cost to ourselves, we have continued to collect genuine portable batteries from retailers across the UK, maintaining collections that other operators have found uneconomic precisely because the current framework does not reward the effort. We work closely with partners including Duracell to run joint initiatives alongside retailers specifically designed to increase consumer recycling rates, not simply to generate compliance evidence. We know from direct operational experience that collection rates can be moved significantly through the right combination of in-store infrastructure, consumer messaging and retailer engagement.

As the UK’s largest battery compliance scheme and its largest collector of actual portable batteries, we are not commenting from the outside. We are the largest participant in the system, and we are saying clearly that the proposed mechanism will not work.

The upcoming regulatory reform is an opportunity to put in place a system that genuinely drives collection rates, supports UK recycling capacity and delivers against the policy objectives that the lead acid workaround has been obscuring for years.

That means chemistry-based modulated fees that create real obligations for schemes to address the battery types their members are actually selling. It means direct investment in consumer-facing collection infrastructure, particularly for lithium batteries, that makes proper disposal easy and accessible. It means honest scrutiny of whether compliance-fee-funded programmes are delivering measurable outcomes rather than simply spending money and reporting on activities. And it means using the genuine expertise of specialist battery collectors and scheme operators who have been building this infrastructure at their own cost while the framework has allowed others to take an easier route.

The WEEE compliance fee has had years to demonstrate that the model works. The Material Focus data tells a clear story about the results. Repeating that model for batteries, at a moment when the stakes around lithium battery safety are higher than ever, would be a missed opportunity that the sector will be living with for a long time.