How to Dispose of Batteries: A UK Business Guide

To dispose of batteries as a business, sort them by type and chemistry, protect the terminals, store them in a suitable container away from general waste, and hand them to a licensed carrier for recycling at a permitted treatment facility. Industrial and automotive batteries must never go to landfill or incineration, and many battery types are classed as hazardous waste. Keep the waste transfer note or hazardous waste consignment note for every collection.

This guide covers each battery type a commercial site is likely to produce, what the law requires, and the practical steps that keep your site safe and your paperwork in order.

The law on battery disposal in the UK

The main legislation is the Waste Batteries and Accumulators Regulations 2009. It splits batteries into three groups, and the rules differ for each:

• Portable batteries are sealed, can be hand-carried by an average person without difficulty, and are neither automotive nor industrial. Think AA and AAA cells, button cells, laptop and phone batteries, and power tool packs.
• Industrial batteries are designed exclusively for industrial or professional use, power electric vehicles, or are sealed but too heavy to count as portable. Examples include UPS batteries, forklift traction batteries, emergency lighting packs and battery storage systems.
• Automotive batteries are those used for vehicle starter, lighting or ignition power.

Regulation 56 states that no person may dispose of waste industrial or automotive batteries in a landfill or by incineration. On top of the battery rules, every business has a legal duty of care for the waste it produces. That means storing it safely, using an authorised waste carrier and keeping records. Our waste duty of care guide explains those duties in full.

Defra and the devolved governments are working on reforms to battery producer responsibility, with a UK-wide consultation expected. At the time of writing the 2009 Regulations remain in force, so the steps below reflect the current rules.

Which batteries are hazardous waste?

Hazardous status depends on chemistry, not size. GOV.UK guidance on classifying waste electrical equipment and batteries sets out the waste codes for business waste as follows:

• Lead-acid (vehicle and other): hazardous, 16 06 01*
• Nickel-cadmium (NiCd): hazardous, 16 06 02*
• Mercury-containing batteries: hazardous, 16 06 03*
• Alkaline batteries: non-hazardous, 16 06 04
• Lithium and lithium-ion batteries: non-hazardous, 16 06 05
• Separately collected mixed household-type batteries: hazardous, 20 01 33*

The asterisk marks a hazardous code. Two points catch people out. First, a mixed box of batteries is treated as hazardous, so one lead-acid or NiCd battery in a tub of alkalines changes how the whole container is handled. Second, a non-hazardous waste code does not mean a battery is low risk. Lithium batteries are classed as dangerous goods for transport and are a leading cause of fires in waste vehicles and recycling sites. Our article on lithium battery fires at work looks at that risk in detail.

Where batteries are hazardous, you must use a hazardous waste consignment note when they leave your site, and you must not mix them with other waste. See our hazardous waste regulations guide for the full picture.

How to dispose of batteries by type

Portable batteries

Offices, shops, schools and maintenance teams produce a steady flow of AA, AAA, 9V, button cells and rechargeable packs. Collect them in a dedicated, lidded, non-conductive container. Keep alkaline, lithium and rechargeable types apart where you can, because separate streams make classification accurate and reduce fire risk. Shops that supply 32kg or more of portable batteries a year must let anyone return waste portable batteries free of charge, without buying anything, but these points are built for small household quantities. A site producing batteries regularly needs a commercial collection with proper paperwork.

Industrial batteries

UPS and standby batteries, traction batteries, emergency lighting packs and energy storage modules are industrial batteries. The producer that supplied them must take back waste industrial batteries free of charge on request in certain circumstances, such as when it supplies you with new batteries. Many businesses also use a specialist recycler so that every chemistry goes through one route. Industrial batteries are often heavy and may hold a residual charge, so plan safe handling and lifting before removal. Large battery energy storage systems need a planned decommissioning and isolation process before removal.

Automotive (lead-acid) batteries

Garages, fleet depots and plant hire firms are usually the final holder of automotive batteries. Producers of automotive batteries must collect them free of charge from final holders on request. Lead-acid batteries contain sulphuric acid and lead, so store them upright on a bunded, acid-resistant surface, keep caps and vents intact and never stack them in a way that could crush the casing. They are hazardous waste and need a consignment note when collected.

Lithium-ion batteries

Lithium-ion cells need the most care. Tape the terminals, keep them out of direct sunlight and away from heat, separate damaged cells and store them in a fire-safe container. We cover storage, transport and fire risk in our dedicated guide on how to dispose of lithium batteries.

Batteries inside equipment

Laptops, phones, power tools, vapes, handheld scanners and emergency lights all contain batteries. Where a battery is designed to be removed easily, take it out and collect it in your battery stream. Where it is sealed in, do not try to cut or prise it out, as damaging a cell can start a fire. Send the whole item for electrical waste recycling and tell your contractor it contains a battery.

Damaged, leaking or swollen batteries

Treat any battery that is swollen, cracked, leaking, hot or crushed as higher risk. Isolate it from other batteries, prevent short circuits, keep it away from heat and water, and store it in a separate fire-safe container. Do not try to charge it or put it back in service. Tell your waste contractor before collection, because damaged batteries need different packaging for transport.

How to store batteries before collection

1. Tape the terminals. Use non-conductive tape over exposed terminals on lithium, 9V and larger batteries, or bag each battery individually, so terminals cannot touch metal or each other.
2. Use the right container. A lidded, non-conductive container for portable batteries; a fire-safe container for lithium; a bunded, acid-resistant area for lead-acid.
3. Segregate by chemistry. Keep lead-acid, NiCd, lithium and alkaline batteries apart, and keep damaged batteries on their own.
4. Choose the location carefully. Cool, dry, ventilated, out of direct sunlight, away from combustible materials and not on an escape route.
5. Label everything. Mark each container with its contents so staff and drivers know what they are handling.
6. Keep quantities low. Book regular collections rather than letting batteries build up on site.
7. Include batteries in your fire risk assessment. The Regulatory Reform (Fire Safety) Order 2005 requires a suitable and sufficient fire risk assessment, and battery storage should be part of it.

Paperwork you need for battery disposal

• Waste transfer note for non-hazardous batteries such as alkaline and lithium. Both parties keep a copy for two years. A season ticket can cover repeated transfers of the same non-hazardous waste for up to a year. Read our waste transfer note guide for what to include.
• Hazardous waste consignment note for lead-acid, NiCd, mercury and mixed batteries. In England, producers keep consignment notes and related records in a register for three years.
• Carrier and site checks. Confirm your carrier is registered and the receiving site holds the right permit. A battery should only go to a site with the appropriate permit or exemption.

Rules vary across the UK. In Wales, premises producing or storing more than 500kg of hazardous waste a year must register with Natural Resources Wales every 12 months. In Northern Ireland, hazardous waste movements must be pre-notified to NIEA at least 72 hours beforehand. In Scotland, hazardous waste is known as special waste and SEPA requires special waste consignment notes. Digital Waste Tracking also became mandatory for receiving sites in England, Wales and Northern Ireland from October 2026, and existing paperwork continues alongside it for now.

Common battery disposal mistakes

• Putting batteries in general waste or mixed recycling, where they can be crushed in a vehicle and start a fire.
• Throwing every battery into one tub with exposed terminals.
• Storing damaged lithium batteries alongside healthy ones.
• Letting lead-acid batteries pile up outside, unbunded and exposed to the weather.
• Paying for collection but keeping no waste transfer notes or consignment notes.
• Pulling sealed batteries out of equipment by force.

Frequently Asked Questions

Can businesses put batteries in general waste?

No. Batteries should be collected separately and sent to a permitted treatment facility. It is illegal to send waste industrial or automotive batteries to landfill or incineration, and hazardous batteries must not be mixed with other waste.

Are batteries classed as hazardous waste?

Some are. Lead-acid, nickel-cadmium, mercury-containing and mixed batteries are hazardous. Alkaline and lithium batteries carry non-hazardous waste codes, although lithium batteries are still dangerous goods for transport and a serious fire risk.

Do I need to tape batteries before recycling?

Taping the terminals of lithium, 9V and larger batteries with non-conductive tape, or bagging them individually, prevents short circuits in storage and transport. It is one of the simplest ways to reduce fire risk.

Who pays for industrial battery recycling?

Battery producers must take back waste industrial batteries free of charge from end users in certain circumstances, such as when they supply new batteries. Many businesses also use a specialist recycler so every chemistry is handled through one documented route.

What paperwork do I need when batteries are collected?

A waste transfer note for non-hazardous batteries, kept for two years, and a hazardous waste consignment note for hazardous batteries. In England, hazardous waste records are kept in a register for three years.

How Waste Experts handles battery recycling

Waste Experts is an Approved Battery Treatment Operator (ABTO) and runs its own permitted treatment facility at Kirkheaton, Huddersfield. We collect every chemistry a commercial site produces, from portable and alkaline batteries to lithium-ion, lead-acid, NiCd and NiMH, plus batteries sealed inside equipment. We supply fire-safe containers for storage, our ADR-trained drivers collect on a schedule that keeps on-site quantities low, and you receive Duty of Care documentation for every collection.

Batteries are treated at our own site rather than passed on to third parties, and lithium-ion is kept segregated throughout. If you place batteries on the UK market, our sister compliance scheme WERCS can help with producer obligations. Find out more about our battery recycling service.

Business customers only. Waste Experts collects from businesses and organisations, not households, and CEF branch drop-off is for business waste only. If you are getting rid of waste from your home, use your council's household waste recycling centre or a retailer take-back scheme instead.