Approval of Call2Recycle's Revised District Battery Stewardship

GOVERNMENT OF THE DISTRICT OF COLUMBIA

Department of Energy and Environment

1200 First Street NE, 5th Floor, Washington, DC 20002|(202) 535-2600|doee.dc.gov

August 4, 2023

Carin Stuart, Steward Relations Manager

Call2Recycle

1000 Parkwood Circle, Suite 200

Atlanta, GA 30339

Re: Approval of Call2Recycle’s Revised District Battery Stewardship Plan, submitted August 4,

2023

Dear Ms. Stuart:

This letter presents the determination of the Department of Energy & Environment (DOEE) on

Call2Recycle’s Revised District Battery Stewardship Plan, submitted August 4, 2023 (“revised

plan”).

DOEE has determined that the revised plan complies with the requirements of D.C. Official

Code § 8-771.03(a) and 20 DCMR § 3900 et seq. Accordingly, we are approving the revised

plan. We have also attached the final version of the plan to this letter.

D.C. Official Code § 8-771.02(b) states: “A battery stewardship organization shall implement the

battery stewardship plan no later than 90 days after the plan is approved.” As DOEE is approving

this plan on August 4, 2023, the deadline for implementation of this plan is November 2, 2023.

DOEE appreciates your dedication to ensuring the plan meets the requirements of the battery

stewardship law and regulations. We look forward to working with you as the District’s battery

stewardship program moves forward.

Sincerely,

Maribeth DeLorenzo

Deputy Director

Urban Sustainability Administration

DISTRICT BATTERY STEWARDSHIP PLAN

Pursuant to

D.C. Official Code § 8-771.01 to .10

Final Plan Approved August 4, 2023

Submitted by:

Call2Recycle, Inc.

1000 Parkwood Circle, Ste. 200

Atlanta, GA 30339

www.call2recycle.org

Submitted to:

District of Columbia

Department of Energy & Environment

1200 First Street NE

Washington, DC 20002

productstewardship@dc.gov

TABLE OF CONTENTS

I. INTRODUCTION .................................................................................................................................................................................................. 4

A. T

HE DISTRICT BATTERY LAW AND REGULATIONS .................................................................................................................................................. 4

B. C

ITATIONS ..................................................................................................................................................................................................... 5

II. S

TEWARDSHIP ORGANIZATION .............................................................................................................................................................................. 5

A. C

ITATIONS ..................................................................................................................................................................................................... 5

B. C

ALL2RECYCLE, INC. ....................................................................................................................................................................................... 6

C. M

ANAGEMENT AND ADMINISTRATION .............................................................................................................................................................. 6

III. R

EGISTERED PRODUCERS AND BRANDS .................................................................................................................................................................. 6

A. C

ITATIONS ..................................................................................................................................................................................................... 6

B. B

ATTERY PRODUCERS AND BRANDS ................................................................................................................................................................... 7

C. F

REE COLLECTION ........................................................................................................................................................................................... 7

IV. A

NTICIPATED BUDGET & FINANCING ..................................................................................................................................................................... 7

A. C

ITATIONS ..................................................................................................................................................................................................... 7

B.

PRO FORMA BUDGET ....................................................................................................................................................................................... 8

C.

FINANCING THE STEWARDSHIP PROGRAM ..................................................................................................................................................... 10

V.

PERFORMANCE GOALS ................................................................................................................................................................................... 11

A

.

CITATIONS ................................................................................................................................................................................................ 11

B.

COLLECTION RATES .................................................................................................................................................................................... 12

C.

RECYCLING EFFICIENCY RATES (RER) ............................................................................................................................................................ 14

D.

PUBLIC AWARENESS .................................................................................................................................................................................. 14

E.

CONVENIENCE AND ACCESSIBILITY ................................................................................................................................................................ 16

V

I.

COLLECTIONS & ACCESSIBILITY ......................................................................................................................................................................... 16

A

.

CITATIONS ................................................................................................................................................................................................ 16

B.

COLLECTIONS ............................................................................................................................................................................................ 17

C.

ACCESSIBILITY & CONVENIENCE ................................................................................................................................................................... 21

D.

ROLES AND RESPONSIBILITIES ...................................................................................................................................................................... 22

V

II.

RECYCLING OF BATTERIES: TRANSPORTERS, SORTERS & PROCESSORS .................................................................................................................... 22

A

.

CITATIONS ................................................................................................................................................................................................ 22

B.

SORTING FACILITIES ................................................................................................................................................................................... 23

C.

PROCESSING STANDARDS & DUE DILIGENCE .................................................................................................................................................. 23

D.

PRIMARY BATTERY PROCESSORS .................................................................................................................................................................. 25

E.

RECHARGEABLE BATTERY PROCESSORS ......................................................................................................................................................... 28

F.

SAFETY AND COMPLIANCE .......................................................................................................................................................................... 36

G.

TRAINING ................................................................................................................................................................................................. 36

H.

PERIODIC SORTING .................................................................................................................................................................................... 37

V

III.

PLAN PARTICIPANTS ....................................................................................................................................................................................... 37

A

.

CITATIONS ................................................................................................................................................................................................ 37

B.

COLLECTION SITES ................................................................................................................................................................................... 38

C.

TRANSPORTERS ......................................................................................................................................................................................... 41

D.

SORTERS ................................................................................................................................................................................................. 42

E.

PROCESSORS ............................................................................................................................................................................................ 42

IX

.

EDUCATION & OUTREACH............................................................................................................................................................................... 44

A

.

CITATIONS ................................................................................................................................................................................................ 44

B.

EDUCATION & OUTREACH PRACTICES ........................................................................................................................................................... 45

C.

STRATEGIES, TACTICS & DELIVERABLES ......................................................................................................................................................... 47

D.

ADDITIONAL ENHANCEMENTS & CONTINUOUS IMPROVEMENTS ....................................................................................................................... 52

APPENDIX A - PRODUCERS IN CALL2RECYCLE PROGRAM ............................................................................................................................................... 53

APPENDIX B - USDOT SPECIAL PERMIT 14849 .......................................................................................................................................................... 72

APPENDIX C - TERMINAL PROTECTION ....................................................................................................................................................................... 80

APPENDIX D – R2 CERTIFICATION ............................................................................................................................................................................. 81

APPENDIX E – SAMPLE PROGRAM MATERIALS ............................................................................................................................................................ 82

APPENDIX F – EXAMPLE OF COLLECTION PARTNER SAFETY TRAINING ............................................................................................................................... 84

APPENDIX G - PROCESSOR HAZARDOUS WASTE PERMIT DETAILS ................................................................................................................................... 85

4

I. INTRODUCTION

Call2Recycle, Inc., which administers the Call2Recycle

®

program, is a non-profit, public service

organization. Since 1996, on behalf of battery producers, Call2Recycle has managed a

rechargeable battery collection and recycling program in the District. Call2Recycle, Inc. is

registered as a battery stewardship organization (“BSO”) under the District’s battery stewardship

law. Pursuant to D.C. Official Code § 8-771.04(a)(1), Call2Recycle, Inc. is submitting this plan to

the District to create and manage a mandatory battery stewardship program for all battery

chemistries, expanding its existing rechargeable program to include primary batteries.

Call2Recycle's plan builds and learns from the past 25

+

years of operating in the District. With the

participation of the District, retailers, businesses, manufacturers, and residents, and the passage

of the District's extended producer responsibility legislation, Call2Recycle seeks to enable the

District to collect primary and rechargeable batteries. Per § 8–771.01, an in-scope primary battery

is defined as a non-rechargeable battery that weighs 4.4 pounds (2 kilograms) or less, including

alkaline, carbon-zinc, and lithium metal batteries, and an in-scope rechargeable battery is defined

as a battery that contains one or more voltaic or galvanic cells, electrically connected to produce

electric energy, designed to be recharged, that weighs less than 11 pounds (5 kilograms) and has

a Watt-hour rating of no more than 300 Watt-hours, unless an exclusion applies. Further

references to primary and rechargeable batteries in this plan mean the batteries meet these

definitions in the D.C. Code.

A. The District Battery Law and Regulations

The amendments to the Sustainable Solid Waste Management Amendment Act of 2014 require

the battery stewardship organization to submit a Battery Stewardship Plan to the District

Department of Energy and Environment ("DOEE") for review and approval.

The Battery Stewardship Plan must include, at a minimum, all the following requirements:

(a) A proposed battery stewardship plan shall include, at a minimum:

(1) A list of producers and brands, including:

(A) All producers participating in the battery stewardship plan and contact information for each of the

participating producers;

(B) The brands of batteries and battery-containing products covered by the battery stewardship plan; and

(C) Brands of products meeting the exemption described in § 8-771.01(2)(B) that contain batteries supplied

by producers participating in the battery stewardship plan;

(2) An anticipated annual budget for the battery stewardship plan, broken down into administrative,

collection, transportation, disposition, and communication costs, along with a description of the financing

method used to implement the battery stewardship plan. The budget shall fund, at a minimum, staff

responsible for implementing the battery stewardship plan in the District and include funds for fees

administered by DOEE. The budget may not include legal fees or costs related to legislative efforts;

(3) Economically and technically feasible performance goals for each of the first 3 years of implementation

of the battery stewardship plan that are based on the estimated total weight of primary and rechargeable

batteries that have been sold in the District in the previous 3 calendar

years by the producers participating

in the battery stewardship plan;

(4) A description of how the battery stewardship organization will provide for the convenient collection of

primary and rechargeable batteries from consumers as required by § 8-771.02(a). At a minimum, the battery

stewardship plan shall provide for a minimum of one collection site per 10,000 people in the District, with a

5

reasonable geographic spread of collection sites across all 8 wards, taking into account accessibility to public

transit, and an explanation for the geographic spread; except, that DOEE shall not require the collection site

minimum in this paragraph to be met in the first year of implementation of the plan if the plan provides a

reasonable timetable for achieving that requirement;

(4A) A description of how the battery stewardship organization will develop strategies, in consultation with

DOEE and other relevant parties, for collecting primary and rechargeable batteries in areas and communities

that face environmental justice challenges associated with waste management;

(5) A description of how the battery stewardship organization will arrange for components of the discarded

batteries to be recycled to the maximum extent economically and technically feasible, in a manner that is

environmentally sound and safe for waste management workers;

(6) A list of all key participants in the battery collection program, including:

(A) The names of the collection sites accepting batteries under the plan, including the address and contact

information for each collection site;

(B) The name and contact information of a transporter or contractor collecting batteries from the collection

sites; and

(C) The name, address, and contact information of the recycling facilities that process the collected batteries;

(7) A description of the education and outreach that will be used to inform consumers about the battery

collection program, which must, at a minimum, notify the public that there is a free collection program for

all primary and rechargeable batteries as well as the location of the collection sites and how to access the

battery collection program; and

(8) Other information as required by the Mayor through rulemaking.

The plan must also meet the requirements for battery stewardship plans in Title 20, Chapter 39,

of the District of Columbia Municipal Regulations (“DCMR”).

B. Citations

To provide the appropriate framework, each section of this plan begins with the citation(s) of the

sections of the Law and regulations pertaining to it.

II. STEWARDSHIP ORGANIZATION

A. Citations

Statutory Citation

(b) Beginning January 1, 2022, and annually thereafter, a battery stewardship organization shall file a

registration form with DOEE. The registration form shall require the following information:

(1) A list of the producers participating in the battery stewardship organization;

(2) For each participating producer, the name, address, and contact information of a person responsible for

ensuring the participating producer's compliance with this chapter;

(3) A description of how the battery stewardship organization proposes to meet the requirements of

subsection (a) of this section, including any reasonable requirements for participation in the battery

stewardship organization; and

(4) The name, address, and contact information of a person for a nonmember producer to contact on how

to become a member of the battery stewardship organization.

Regulatory Citation

Regulations establishing requirements for battery stewardship organizations can be found at 20 DCMR

3900.

6

B. Call2Recycle, Inc.

Call2Recycle, Inc., is a 501(c)4 non-profit public service organization organized under Delaware

law. The Call2Recycle

®

program was created and funded by battery and product manufacturers

committed to responsible recycling.

Founded in 1994 as the Rechargeable Battery Recycling Corporation (RBRC), Call2Recycle is the

first and most extensive U.S. consumer battery stewardship program, collecting used primary and

rechargeable batteries and used cellphones. The Call2Recycle program has operated in the

District since its collection program launched in 1996.

Call2Recycle, Inc., is led by an experienced Senior Leadership Team and governed by its

Board of

Directors.

C. Management and Administration

Call2Recycle, Inc., is responsible for the management and administration of the program,

including, but not limited to, the following tasks:

• Management of program communications

• An interface for the public and with parties contracted under the program

• Overall day-to-day management of the program, including liaison with other

stakeholders and the District government

• Collection of stewardship fees through a process that ensures the confidentiality of data

• Defining and meeting the performance management targets for the program, including

a plan for continuous improvement

• Ensuring compliance with all applicable District, federal, state, and municipal requirements

• Management of contracts with the collection, sorting, processing, and recycling service

provider(s) and the audit functions

• Setting and adhering to operating budgets

III. REGISTERED PRODUCERS AND BRANDS

A. Citations

Statutory Citation

(a) A proposed battery stewardship plan shall include, at a minimum:

(1) A list of producers and brands, including:

(A) All producers participating in the battery stewardship plan and contact information for each of the

participating producers;

(B) The brands of batteries and battery-containing products covered by the battery stewardship plan; and

(C) Brands of products meeting the exemption described in § 8-771.01(2)(B) that contain batteries supplied

by producers participating in the battery stewardship plan;

Regulatory Citation

3902.1 A proposed battery stewardship plan shall include:

(a) A list of producers and brands, including:

7

(1) The name of each BSO member and the name, mailing address, phone number, and email address of a

contact for each BSO member;

(2) The brands of batteries and battery-containing products covered by the battery stewardship plan; and

(3) A description, including brand name, product name, producer name, and other identifying information,

of products that will be exempt under § 3901.2 when the proposed battery stewardship plan is approved;

B. Battery Producers and Brands

As of July 7, 2023, 194 producers, representing 478 brands, have designated Call2Recycle, Inc. as

their battery stewardship organization to fulfill their compliance requirements under the District's

battery stewardship law. These producers will finance primary and rechargeable battery

collection and recycling in the District by paying fees based on the total weight of in-scope

batteries sold into the jurisdiction.

A listing of producers and their contact information, as well as covered brands partnering with

Call2Recycle to comply with the District battery stewardship law, can be found in Appendix A.

Upon the program's launch, currently planned for November 1, 2023, Call2Recycle will provide

the District with a final list of Call2Recycle District program stewards, which are BSO “members”

as described in the District’s battery stewardship law and regulations.

1

Please note that

Call2Recycle may adjust timing depending on final plan approval.

Call2Recycle will utilize The District of Columbia Battery Stewardship Exemption Certification

document to formalize the implementation of the exemption described in section 20 DCMR §

3901.2(a) and (b). At the date of submittal of this revised plan, no battery-containing product is

exempt, and no battery-containing product will be exempt upon plan approval unless the

producer of each primary or rechargeable battery contained in the product or packaged with the

product at the time of sale has complied with the requirements of 20 DCMR § 3901.2(a) and (b).

As of August 1, 2023, one producer has started the process to exempt a battery-containing

product under 20 DCMR 3901.2. Appendix A includes a description of the product, including brand

name, product name, producer name, and other identifying information, that will be exempt

under § 3901.2 when the proposed battery stewardship plan is approved.

C. Free Collection

With funding from participating producers, Call2Recycle's collection and recycling program will be

offered to District consumers at no cost, to accept all batteries meeting the legal definition of a

battery as described in the Introduction. In addition, participation in the Call2Recycle program as

a battery collection site (assuming the entity meets the collection site criteria listed in Section VI

of this Plan) is open at no cost to all retailers and other entities, such as solid waste management

facilities, as long as the sites meet Call2Recycle's standards, including completing an online safety

tutorial. Conversely, no organization is required to participate as a collection site.

IV. ANTICIPATED BUDGET & FINANCING

A. Citations

1

The term “members” as used in this plan relates solely to participation in the District Battery Stewardship Plan

and has no other legal meaning.

8

Statutory Citation

(2) An anticipated annual budget for the battery stewardship plan, broken down into administrative,

collection, transportation, disposition, and communication costs, along with a description of the financing

method used to implement the battery stewardship plan. The budget shall fund, at a minimum, staff

responsible for implementing the battery stewardship plan in the District and include funds for fees

administered by DOEE. The budget may not include legal fees or costs related to legislative efforts;

Regulatory Citation

(b) An anticipated annual budget for the plan’s implementation that:

(1) Covers the first partial calendar year, if any, of battery stewardship plan implementation and the first

full calendar year of implementation following any partial year;

(2) Lists separate line items for the following categories: (A) Battery stewardship plan administration costs;

(B) Collection costs;

(C) Transportation costs;

(D) Disposition costs, including separate line items for the cost of recycling, other processing, and end-of-life

handling; and

(F) Communication costs, which shall have the same meaning as public education program costs used in §

3900.1(d) and public education and outreach program costs used in § 3903.3(k)(1);

(3) Describes the financing method used to implement the battery stewardship plan, identifies funding for

staff responsible for implementing the battery stewardship plan in the District, and includes DOEE

administration fees established by § 3907; and

(4) Does not include legal fees or costs related to legislative efforts;

B. Pro Forma Budget

The following is the budget for the calendar years 2023 – 2024. Note that 2023 includes the

program being operational for just the last two months of the calendar year per the dates in the

regulation as enacted. Also, since the final program participants will not be known before

November 1, 2023, the revenue (and implied collections) shown below reflects estimated

producer fees.

This will be updated and submitted around the program's launch, scheduled for November 1,

2023.

The collection rate used to determine collection expenses reflects the performance goals

discussed in Section V. The definition of the categories of "costs" are as follows:

• "Collections" includes the costs for manufacturing the collection kits including the containers;

bags; additional collection materials which are collateral and related material which includes

kiosks and in-store signage; the costs for managing the kits in inventory; and the costs for

picking and managing the orders for the kits. All battery stewardship plan collection sites in

the program must use Call2Recycle’s own collection kits.

• "Transportation" includes the costs of shipping collection kits to a collection site, the costs of

shipping collection kits to sorters or consolidation facilities, and the costs of shipping the

sorted material to downstream processors. These costs were estimated based on insights

gleaned from the previous 25+ years of operating a rechargeable program in the District and

a primary battery program in Vermont.

• "Disposition" is the cost for recycling and sorting associated to the downstream treatment.

These costs were estimated based on insights gleaned from the previous 25+ years of

operating a rechargeable program in the District and a primary battery program in Vermont.

9

Section VII describes all disposition completed at each processing facility. The breakdown of

costs for recycling and management/treatment/disposal (i.e., end-of-life handling) of

materials by downstream vendors cannot be separated out therefore only one line item for

disposition is provided.

• “Total Operations” includes collections, transportation, disposition, and required periodic

sorting budgeted for the first two months of the program. In the subsequent year, the budget

includes funding for supplemental collection that may be in the form of a mailer, collection

events, or other service that supplements permanent collection sites in the District.

• “Professional fees” includes the allocated expenses associated with the annual Call2Recycle

financial audit and are based on the percentage of fees for the District program as a portion

of the national steward program.

• "Overhead" includes the costs for information technology (IT), finance, customer service, and

other miscellaneous overhead.

• "Start-Up Costs" are for the one-time costs incurred in the first two months of the District

program set-up for legal support pertaining to Call2Recycle agreement documentation,

expansion of the collection footprint, and development costs in advance of the program

launch. The budget does not include legal fees or costs related to legislative efforts.

• “Battery Stewardship Plan Administration” includes all administrative costs associated with

operating the Call2Recycle program in the District including salary & benefits; professional

fees; travel, meals, and lodging; overhead; and start-up costs.

• "Communication Costs" includes costs for all outreach to all stakeholders, including but not

limited to retailers, consumers, and collection sites.

• "DOEE" reflects payments prescribed by Law to support the District's program oversight.

10

TABLE 1. Battery Product Stewardship Plan – District of Columbia

by Calendar Year

*Estimated inflation at 3% for budgeting purposes.

** Revenue timeframe is April through December.

Notable highlight of the budget:

• The budget assumes the equivalent of two full employees assigned to the District program,

supported by central personnel in communications, finance, operations and IT.

C. Financing the Stewardship Program

The financing of the District's battery stewardship program has been derived from obligated

battery producers' fees and obligated battery-containing product producers’ fees and approved

by the Call2Recycle Board of Directors. Obligated producers are those entities that meet the

definition of “Producer” in § 8–771.01(11).

Nov. - Dec.

2023**

2024

Revenue

Primary

246,390$ 492,781$

Rechargeable

8,970$ 21,614$

TOTAL REVENUE

255,360$ 514,395$

Expenses

Collections

$ 26,176 $ 34,879

Transportation $ 1,362 $ 11,445

Disposition $ 822 $ 6,904

Recycling $ 329 $ 2,855

Sorting $ 493 $ 4,049

Annual periodic sort $ 10,000 $ 10,000

Supplemental collection $ - $ 65,000

Total Operations

38,360$ 128,228$

Salary & Benefits

31,250$ 137,500$

Professional Fees

24,775$ 47,754

$

Travel, Meals & Lodging

5,000$ 5,000$

Overhead

23,720$ 35,732$

Start-up Costs

15,000$ 15,000$

Battery stewardship plan

administration

99,745$ 240,986$

Communication Costs

45,000$ 100,000$

DOEE

40,000$ $ 41,200*

TOTAL EXPENSE

223,105$ 510,414$

NET REVENUE / EXPENSE

32,255$ 3,980$

Margin %

13% 1%

11

After each calendar quarter, producers as defined in § 8–771.01(11), which includes producers of

both covered battery and covered battery-containing products, are required to report their

estimated sales of in-scope batteries by weight into District's market for the previous quarter.

The reporting is for in-scope battery weight only and not the product that the battery may be

powering. If the obligated battery producer cannot break out sales into the District from its

national data, estimates of in-scope batteries sold in the District will be calculated by dividing the

District’s population by the U.S. population (currently 0.20%) and multiplying this figure by the

national sales weight. Fees are established by chemistry, given the different costs associated with

collecting, handling, sorting, and recycling them. Start-up costs for the District program will be

reported for Q2 2023 ahead of program launch in Q4 2023. Start-up costs are financed in the same

manner as described above.

Battery weights are reported through Call2Recycle's secure online portal, GreenTrax, which

immediately generates an invoice upon completing the sales reporting process. The fees will be

adjusted no more frequently than annually, representing the increased costs of continually

increasing the amount of in-scope batteries collected.

V. Performance Goals

A. Citations

Statutory Citation

(3) Economically and technically feasible performance goals for each of the first 3 years of implementation

of the battery stewardship plan that are based on the estimated total weight of primary and rechargeable

batteries that have been sold in the District in the previous 3 calendar years by the producers participating

in the battery stewardship plan;

Regulatory Citation

(c) Economically and technically feasible performance goals that:

(1) Include metrics to measure, on an annual basis, the performance of the plan, taking into consideration

technical feasibility and economic practicality, in achieving continuous, meaningful progress to improve the

rate of battery recycling in the District;

(2) Cover each of the first three (3) full calendar years of battery stewardship plan implementation;

(3) Discuss how the BSO will address performance goals during the first partial calendar year, if any, of

battery stewardship plan implementation;

(4) Are in the form of target collection rates, target recycling efficiencies by battery recycling process, and

measurable goals for public awareness, convenience, and accessibility;

(5) With respect to target collection rates, are based on the estimated total weight, calculated according to

§ 3904, of primary and rechargeable batteries, including batteries contained in or sold with battery-

containing products, that are sold in the District in the previous three (3) calendar years by the BSO

members;

(6) With respect to goals for recycling efficiencies by battery recycling process:

(A) Include a method for calculating recycling efficiency; and

(B) Provide target recycling efficiencies by battery recycling process;

(7) With respect to goals for public awareness:

(A) Increase the percentage of people in the District who know how to recycle primary and rechargeable

batteries through stewardship plan collection sites; and

(B) Include measures to evaluate progress in increasing public awareness in the District, such as advertising

and media impressions and social media engagement; and

12

(8) With respect to goals for convenience and accessibility, include metrics to evaluate:

(A)The proximity of collection sites to residents in all eight (8) District wards;

(B)The extent to which collection sites across the District are open to the public, including the hours and days

that collection sites are open and whether there are any limitations on public entry;

(C)Accommodations for people with limited or no English proficiency; and

(D) The availability and effectiveness of any mail-back or other program proposed under § 3902.3;

B. Collection Rates

For two months in 2023, Call2Recycle is proposing a collection rate of 0.35% based on data from

other jurisdictions, program modifications, and assumptions. This rate, which equates to 2,000

lbs. is for just two months of CY2023 as the program increases collection sites, consumer

outreach, and education. This is compared to 5,042 lbs. batteries collected in the District for a full

year in 2022. Subsequent years' proposed collection rates will increase as collection sites are

established and sufficient time has passed to educate and positively impact consumer behavior.

This rate is different when compared with other Nations, Provinces, and Jurisdictions because

different historical factors influence consumer behavior to recycle batteries at end of life. For

example, in Vermont, long-established consumer behavior has been for residents to know that

batteries can be recycled at end of life and to take the appropriate action to recycle batteries.

Therefore, at the start of the program, we considered this longstanding and pre-existing consumer

behavior activity and anticipated a high collection rate early in the Vermont program. In Europe,

it has been a longstanding consumer behavior to recycle many items, including batteries, many

years before the 2006 Battery Directive was made effective. Therefore, consumers were already

accustomed to recycling batteries and resulting in initial collection rates in most countries in 2006

meeting the higher criteria in the Battery Directive. As this is not the case in the District, a key

objective of the Education and Outreach plan is to educate consumers in the District that batteries

can and must be recycled, and then motivate them to take action by recycling them. This takes

time through multiple exposures in messaging to achieve a shift in consumer behavior.

The District Battery Stewardship Law is the first U.S. extended producer responsibility regulation

for all consumer primary and rechargeable batteries. As such, no historical U.S. data nor internal

primary battery data is available for Call2Recycle to develop the initial plan's collection rate target

or to compare its ongoing performance.

Therefore, to estimate the average weight of rechargeable batteries offered for sale

2

in the

previous 3 years Call2Recycle used the past 3-year average of the reported rechargeable program

data, with the removal of batteries that are embedded in covered electronic equipment, for the

national Call2Recycle program and proportionally reduced the total U.S. numbers to the District

of Columbia using population as the reducing metric. However, there are many new stewards

joining the program in 2023 because of the District’s implementing regulations which are not

reflected in this historical data.

For primary batteries, Call2Recycle used the historical data for Vermont as the basis for the total

weight of primary batteries offered for sale in the previous three years by stewards. However, the

2

Call2Recycle uses data on batteries offered for sale as the basis for determining collection rates as this is the only

industry data that is available.

13

Vermont law only requires stand-alone replacement batteries to support collection and recycling

of batteries, not primary batteries offered for sale in a device. The total weight of primary

batteries sold in or with devices in the District is currently unknown, as Call2Recycle does not have

historical data to use for calculating.

Projecting collection rate targets four years into the future proved challenging and while they are

estimates only, they do represent Call2Recycle's commitment to continuous improvement.

Call2Recycle will submit updated average sales weight (serving as the denominator for the

collection rate) to the District once it collects the sales data from its producers. Starting at the end

of the 2024 calendar year, Call2Recycle will provide the updated average sales weight for the

calendar year in our annual report.

In accordance with 20 DCMR 3900.1(h) Call2Recycle will submit amended performance goals 2

years after the plan is approved and every two years after that, which may include adjusted

collection rates.

To support continuous and meaningful progress toward increasing the performance goal of the

recycling rate, Call2Recycle has developed an outreach and education plan in Section XI.

TABLE 2: Battery Collection Rates – District of Columbia

Collection Rates by Calendar Years

2023 **

2024

2025

2026

Target Collection Rate

0.35%

2.5%

4.5%

6.5%

Average sales weight offered for sale by

Call2Recycle Stewards (lbs.) in 3

previous calendar years

615,478

(2020-2022)

640,097

(est. 2021-

2023)*

665,701

(est. 2022-

2024)*

692,329

(est. 2023-

2025)*

Estimated Batteries to be Collected

(lbs.)

2,000

16,000

30,000

45,000

* Based on per capita of U.S. sales and an estimated percentage of participating brands. See

"Budget" above. For the years 2024 – 2026, a 4% sales inflation rate was used.

** Note that collections are for two months (November – December) only.

14

C. Recycling Efficiency Rates (RER)

While every take-back program aims to optimize the amount of material collected, it is equally

essential to maximize the amount of material that can be reclaimed for secondary use. This measure

in the battery recycling industry is referred to as the recycling efficiency rate (RER). In short, RER is

the percentage of battery weight received that is not lost in the recycling process and used in

secondary products or materials. RER is calculated by dividing the material recovered from waste in-

scope batteries by the total mass of the waste in-scope batteries that were sent for recycling. The

scope of RER is limited to the facility that receives and processes batteries. RERs are self-reported via

attestation by processors. As a note, subsequent downstream facilities to Call2Recycle approved

processors are often fluid and commercially protected. As such "as far down the recycling chain as

Call2Recycle has visibility" is commonly the same as "the first facility the batteries are sent to". The

RERs outlined in VII will be met in year 1 and re-evaluated every two years as required by District law.

The worldwide standard for RER can be found in the

European Union's 2006 Battery

Directive. In Annex III of this Directive, the RER is prescribed as:

PART B: RECYCLING

3. Recycling processes shall achieve the following minimum recycling efficiencies:

(a) recycling of 65 % by average weight of small sealed lead-acid (SSLA) batteries and

accumulators, including recycling of the lead

content to the highest degree that is technically feasible while avoiding excessive costs;

(b) recycling of 75 % by average weight of nickel-cadmium batteries and accumulators,

including recycling of the cadmium content to the highest degree that is technically

feasible while avoiding excessive costs; and

(c) recycling of 50 % by average weight of other waste batteries and accumulators.

All recycling processors under this plan will meet or exceed the RER's currently in effect in the

European Union.

TABLE 3 Target RER in years 2023 through 2026

Battery Type SSLA Ni-Cd

Alkaline, Lithium Primary,

Li-Ion, Ni-MH

Target RER

65%

75%

50%

D. Public Awareness

Consumer awareness takes time to develop, especially for new or unfamiliar recycling options. While

Call2Recycle will help influence positive consumer awareness through various efforts (as outlined in

Section IX), it is equally as important to understand the effectiveness of the outreach and education

strategies being used to reach those target audiences.

Therefore, Call2Recycle routinely measures consumer awareness regarding key indicators of battery

recycling. It views consumer awareness as a series of ascending knowledge about recycling with the

goal of ever-increasing this knowledge. First, and most importantly, consumers must acknowledge

that recycling is important. Second, they must recognize that primary and rechargeable batteries

15

must be recycled once the disposal ban goes into effect for all people in the District. Next, they must

generally know how to recycle their primary and rechargeable batteries. Finally, they must be

motivated to act on this knowledge. The graphic below shows this ascending awareness.

While collection rate is the best indicator of program performance, the act of returning primary and

rechargeable batteries for collection should not be expected unless a consumer believes that primary

and rechargeable batteries should be recycled and they know how to recycle them [NOTE: generally

speaking, the public believes that recycling is a positive behavior]. As a complement to the collection

rate measure (outlined in Section B under Performance Goals), this plan will track: 1) whether

consumers know that primary and rechargeable batteries can be recycled; and 2) if they have recycled

primary and rechargeable batteries.

In 2022, Call2Recycle utilized a third-party research firm to conduct a consumer online survey using

quotas and weighting to ensure that the survey sample composition reflected that of the District

population according to census information. This research helped to establish a baseline of battery

recycling awareness and incidence in the District, which was used to guide the education and outreach

strategies and tactics. Call2Recycle will conduct the same or similar research annually to measure the

impact of its education efforts. Increasing awareness and behavior at scale is a process that requires

significant time and effort. Call2Recycle commits to gradually increasing battery awareness and

behavior recycling by one (1) percent each year from 2023 until 2026.

Consumer Awareness & Behavior

Baseline

(2022)

2023 2024 2025 2026

Awareness

% of consumers who believe that

household batteries (primary and

rechargeable) can be recycled in the

District

69% 69% 70% 71% 72%

Incidence/Behavior

% of consumers who recycled their

batteries in the District in the past

12 months.

53% 53% 54% 55% 56%

16

E. Convenience and Accessibility

With respect to goals for convenience and accessibility, Call2Recycle is including metrics to

evaluate three specific subjects, as outlined below.

1) The proximity of collection sites to residents in all eight (8) District wards;

Until the end of 2024, the requirement to have a “reasonable geographic spread of collection sites

across all eight (8) District wards that takes into account accessibility to public transit and areas

where people would seek to recycle batteries” will also serve as this performance goal, although

it will still be a requirement. At the end of 2024, this proximity goal will be reevaluated for 2025

and after.

2) The extent to which collection sites across the District are open to the public, including the

hours and days that collection sites are open and whether there are any limitations on public

entry;

Beginning in 2023 through 2026, Call2Recycle will meet that at least 65% of all public collection

sites will have hours outside of 8 am to 5 pm M-F.

3) Evaluate accommodations for people with limited or no English proficiency.

Metric: (a) Call2Recycle will include in its collection site setup a question to each site about what

languages besides English, out of the six language access languages, they would like to receive

signage in and (b) Call2Recycle will send the materials to each site that requests translated

materials.

Goal: completion of (a) for all sites and (b) for those that request materials.

Call2Recycle will provide a mechanism for non-English speaking residents to receive assistance

with finding a drop off location. Future metrics may include the number of downloads of

translated collateral and number of interactions with language services, which may include chat,

call center, locator, and website. In accordance with 20 DCMR 3900.1(h) Call2Recycle will submit

amended performance goals 2 years after the plan is approved and every two years after that,

which will include additional metrics to evaluate accommodations for people with limited or no

English proficiency.

VI. COLLECTIONS & ACCESSIBILITY

A. Citations

Statutory Citation

(4) A description of how the battery stewardship organization will provide for the convenient collection of

primary and rechargeable batteries from consumers as required by § 8-771.02(a). At a minimum, the battery

stewardship plan shall provide for a minimum of one collection site per 10,000 people in the District, with a

reasonable geographic spread of collection sites across all 8 wards, taking into account accessibility to public

transit, and an explanation for the geographic spread; except, that DOEE shall not require the collection site

minimum in this paragraph to be met in the first year of implementation of the plan if the plan provides a

reasonable timetable for achieving that requirement;

(4A) A description of how the battery stewardship organization will develop strategies, in consultation with

DOEE and other relevant parties, for collecting primary and rechargeable batteries in areas and communities

that face environmental justice challenges associated with waste management;

17

Regulatory Citation

(d) A description and explanation of the BSO’s proposed battery collection program, including:

(1) How the BSO will provide for the collection from consumers of all primary and rechargeable batteries,

including batteries contained in or sold with battery-containing products, on a free, regular, convenient, and

accessible basis;

(2) How the BSO will meet the following requirements:

(A) At least one (1) collection site per ten thousand (10,000) people in the District;

(B) A reasonable geographic spread of collection sites across all eight (8) District wards that takes into

account accessibility to public transit and areas where people would seek to recycle batteries;

(C)Safe and legal collection, handling, and shipment of batteries by the collection sites, including ensuring

that each collection site is aware of and adheres to applicable laws and regulations and safety practices for

the collection, handling, and shipment of batteries; and

(D) How the BSO will ensure each collection site has the materials and equipment necessary to handle up to

one hundred (100) batteries per visit and has established a regular pick-up schedule to prevent overflow

issues at the site;

(3) A reasonable timetable for achieving the requirements of § 3902.1(d)(2)(A) and (B), if these requirements

will not be met within the first year of implementation;

(4)A process for decommissioning collection sites, so that if a site closes, any batteries collected until the

closure will be shipped to the proper facilities for recycling as specified in § 3902.1(e), on-site signage about

the availability of drop-off will be removed, and the site will be removed from the public list of collection

sites as specified in § 3902.5; and

(5) How the battery stewardship organization will develop strategies, in consultation with DOEE and other

relevant parties, for collecting primary and rechargeable batteries in areas and communities that face

environmental justice challenges associated with waste management.

B. Collections

Call2Recycle provides a safe, compliant, and free recycling solution for in-scope, consumer

batteries. The program is offered at no cost to sites and the public dropping off their primary and

rechargeable batteries covered under the law. Before the enactment of this regulation,

Call2Recycle had more than 30 active, public and private rechargeable battery collection sites

voluntarily accepting used rechargeable batteries from consumers in District.

Upon approval of the Plan, Call2Recycle will increase its recruiting efforts to add additional

collection sites to the program. Call2Recycle’s recruitment efforts will occur in the below phases

to achieve the requirement of maintaining a minimum of 70 active, public collection sites with a

reasonable geographic spread across all eight Wards that takes into account accessibility to public

transit and areas where people would seek to recycle batteries in the District by December 31,

2024.

Phase 1- Timing: August – November 2023

• Conversion of Existing Sites.

o Audience: Conversion & On-Boarding of existing rechargeable battery sites to all

battery, public collection sites.

o Total Sites: 6 Sites (includes existing Call2Recycle rechargeable battery only

collection sites.) The intent of converting these sites is to establish a foundation

of sites very quickly within the District. These sites are existing, participating

collection sites – these will not be spread evenly throughout the Wards.

18

Phase 2- Timing: August – December 2023

• Step One: Conversion of Existing E-bike Sites.

o Audience: Conversion & On-Boarding of existing e-bike battery collection sites to

all battery, public collection sites.

o Total Potential Sites: 7 Sites (includes existing Call2Recycle e-bike battery

collection sites). These sites are existing, participating collection sites – these will

not be spread evenly throughout the Wards.

• Step Two: Recruitment of New Sites.

o Audience: Recruitment and On-Boarding of non-participating sites to serve as public

collection sites within Call2Recycle’s approved collection site network. The recruitment

of new sites by Call2Recycle will focus on the reasonable geographic spread of sites across

all eight Wards, as well as taking into account accessibility to public transit and areas

where people would seek to recycle batteries. With this in mind, Call2Recycle has

assembled a list of prospect sites for each Ward. Call2Recycle will outreach to a minimum

of 25 potential partners with multiple collection sites to engage their interest in

participating in the program. The goal for this activity will be to add a minimum of 25 new

public collection sites (Target of 38 collection sites by the end of 2023).

o Total Potential Sites: Call2Recycle will outreach to 200 potential sites.

Phase 3- timing: Quarterly, Starting January 1, 2024, to December 31, 2024

• Using Call2Recycle’s prospect list, Call2Recycle will outreach to a minimum of 25 potential

public collection site partners per quarter. The goal of this activity will be to add a minimum

of 12 new public collection sites per quarter.

Once the minimum collection site requirement has been met, Call2Recycle will shift to

maintenance of the participating sites, with adjustments to outreach efforts and tactics as the

program evolves.

Call2Recycle's approach to primary and rechargeable battery collection is designed with user

safety, convenience, and flexibility in mind. Call2Recycle provides the necessary collection

containers and collateral materials to collect primary and rechargeable batteries safely, and pays

all shipping, sorting, and recycling costs.

Call2Recycle's patented collection and shipping box complies with US EPA Universal Waste

regulations, specifically pre-printing the required language on the box, and ships under a U.S.

Department of Transportation Special Permit (Appendix B) allowing both rechargeable and

primary batteries to be collected, stored, and shipped in the same box. In addition, each

collection box comes with a reference guide for terminal protection (Appendix C – Note: this is a

sample of current program materials for rechargeable batteries. Once Call2Recycle's plan is

approved, the reference guide will be updated to include mentions of all batteries.).

In addition, damaged, defective, and recalled (DDR) lithium-based batteries require special

handling per US DOT instruction and cannot be shipped in Call2Recycle’s patented collection and

shipping box. Call2Recycle’s safe battery management tutorial will provide details on identifying

damaged and defective batteries, as well as how to safely transport them for recycling. Public

collection sites, when they open, will be supplied with a damaged and defective battery recycling

kit should they encounter an individual damaged or defective battery. Recalls are the

19

responsibility of the obligated Original Equipment Manufacturer under their recall plan.

Any business, institution, or government entity that wishes to participate as a collection site must

agree to the following:

• Provide contact information for individual sites.

• Safely handle and ship primary and rechargeable batteries in compliance with US DOT

regulations and Call2Recycle program guidance.

• Complete a safety tutorial (minimum of one on-site personnel) on how to safely manage

batteries, to be provided by the battery stewardship organization implementing the

stewardship plan. An example of tutorial slides are found in Appendix F and at this link

.

• Prominently display the availability of drop-off at their location.

• Provide for the acceptance of up to 100 batteries per visit and accept all primary and

rechargeable batteries regardless of type or brand.

• Ensure that collection site personnel responsible for the collection program complete the

tutorial on safe battery management prior to becoming a collection site and when there is a

change in responsible personnel.

• Complete and maintain proper registration with DOEE’s hazardous waste generator status

requirements (Note – Call2Recycle staff will provide direct technical assistance to collection

sites to ensure proper submission of the District’s hazardous waste generator Form 8700-

12. Also, Call2Recycle will work with the District’s Hazardous Waste Section to streamline the

submission process from these collection sites. To comply with DC’s hazardous waste

regulations, sites must also annually submit a self-certification of compliance, properly label

the waste (ex: Universal Waste - Batteries), manage the waste to prevent release (i.e.,

containerize), and demonstrate the waste has not been accumulated for more than one year.

Any collection site wishing to stop participating as a collection site or that closes must notify

Call2Recycle directly to ensure proper handling of any remaining batteries on-site, as well as

their removal from Call2Recycle’s District collection site listing.

Additionally, Call2Recycle will work to ensure D.C. Code § 8-771.03(d)(2) and (3) are met by

participating public collection sites through quarterly collection sites outreach and audits.

Call2Recycle has two different classifications for participating battery collection sites - 1) Public

Collection Sites and 2) Private Collection Sites. Public collection sites (i.e., retailers) provide

regular collection of primary & rechargeable batteries from District consumers as outlined in the

law. Private Collection Sites (i.e., hospitals) collect batteries for recycling from internal use or

customers, but either do not provide regular collection or choose not to be listed as a public drop

off location. Both public and private collection sites will be part of Call2Recycle’s battery

collection program and thus will receive collection materials at no cost.

Public Collection Sites are listed on the Call2Recycle online locator tool which includes links to

their website for consumers to learn the days and hours the site is open to drop off primary and

rechargeable batteries. Public collections sites must be ADA compliant to have their certificate of

occupancy to be open to the public in the District. All collection sites will have Call2Recycle

program materials access via downloads from the website or may request printed materials,

including materials in multiple languages for informing people who have limited or no English

proficiency on how to recycle their primary and rechargeable batteries at the site.

In addition, the below considerations will be included when adding collection sites:

20

• Accessibility – To ensure an optimal number of collection sites available based on the

ordinance minimum requirement of one collection site per 10,000 people in the District, with

a reasonable geographic spread of collection sites across all 8 wards, other geographic

considerations, and population as described in the law and regulations.

• Cost-effectiveness – To manage the program's cost-to-serve, Call2Recycle will consider

several external factors while developing and reviewing its collection site network. For

example, when considering new collection sites, Call2Recycle will review the proximity of

existing collection sites to proposed new ones as it may not make sense to have two sites

close to each other. Environmental health and safety – Call2Recycle will work with companies

that want to enroll to promote environmental health and safety through primary and

rechargeable battery recycling, including lithium battery fire prevention.

Call2Recycle takes proactive measures to ensure that newly enrolled locations are active and

safely participating in the battery collection program. In addition to the necessary containers to

collect used primary and rechargeable batteries, collection sites must take online training on how

to accept and package used primary and rechargeable batteries properly.

All collection sites, new & existing, will be enrolled in Call2Recycle’s site outreach program. Under

the program, each site will receive quarterly (calendar) direct outreach from Call2Recycle

staff. This outreach will be conducted each quarter (at a minimum) via phone, email or in-person,

Call2Recycle staff will reach out to sites to review program requirements (i.e., requirement to

hang poster, accept up to 100 batteries, etc.), shipping, safety compliance (i.e., US DOT

regulations), and how the program works for them. Additionally, should a collection site ship a

non-compliant box (unprotected terminals, overweight, etc.), Call2Recycle staff will contact the

individual collection site at the time the receipt is processed. The site is contacted by email and/or

phone to advise them of the incident, depending on the issue, the site may be suspended from

receiving supplies until the appropriate training and/or other corrective action has taken place.

Call2Recycle supports its customer base by utilizing a centralized fulfillment solution that ships

approximately 200,000 battery collection containers annually to 15,000 US collection

sites. Call2Recycle's box fulfillment solution manages to the following standards:

• Once enrolled and training completed, new collection sites will be provided collection

materials (i.e., collection boxes or drums). For sites using the collection materials, this allows

the site to use one to display and fill, while having an empty back up box available once the

original is filled and sent in. For sites using the bulk option, one (or two) pallet(s) of four, 55-

gallon drums (space dependent) will be sent directly to the site. When all drums on a single

pallet are full, the collection site will use Call2Recycle’s “Battery Shipping Portal” to schedule

a pick-up. The site will then place an order for additional drums (the new drums will not be

delivered when the full drums are picked up – non-dedicated, “Less than truckload” shipments

do not allow for delivery of one item and a pick-up of another). If the site has an additional

pallet of drums, they can continue to collect batteries in those drums. If not, a Call2Recycle

collection box will be provided with the original pallet shipment to ensure they can continue

to collect batteries. Through experience, we do not anticipate more than a few sites using the

bulk shipping option, if any at all.

• New collection sites enrollments are processed and shipped within 2 to 5 business days.

21

•

Collection boxes are sent with a pre-paid return shipping label. Once the box is filled, it is

picked up by the designated carrier.

• An automatic replenishment process for collection sites using Call2Recycle boxes ensures that

participating collection sites have the necessary supplies on-hand for battery

collections. Replacement orders are automatically generated when a filled collection box is

shipped, and the recycling facility records the weight.

• Call2Recycle provides two boxes to all sites. Should sites need more or additional supplies

(i.e., plastic bags), free supplemental orders can be requested via the Call2Recycle Customer

Success team or via an online form. Unless there is an immediate need, over the last 25+ years

of operating a battery collection program, collection sites have reported that they do not have

additional space to store empty boxes and/or the boxes get lost if not used. Call2Recycle will

work with each site to ensure they are aware of their requirements and how to request

guidance or additional supplies.

• Certificates of recycling are available upon request and provide the collector with the weight

of primary and rechargeable batteries recycled based on chemistry type for the requested

period.

In addition to small volumes, Call2Recycle provides a free bulk shipping option for sites with large

volumes of primary and rechargeable batteries to recycle. Under Call2Recycle’s bulk shipping

option, Call2Recycle provides UN rated 55-gallon drum “kits”, which include all the materials,

guidelines, and labels necessary to ensure the “kits” meet US EPA Universal Waste and US

Department of Transportation regulations. Sites can schedule bulk shipments via Call2Recycle's

online "Bulk Shipping Portal" which assists sites in creating a compliant Bill of Lading and allows

for online scheduling of a pickup date.

Any site interested in becoming a collection partner can request more information via the online

participation inquiry

form or by calling toll-free 877-723-1297.

C. Accessibility & Convenience

Call2Recycle has serviced the District since 1996 with its free rechargeable battery collection and

recycling program. To supplement Call2Recycle's historic collection footprint in the District,

Call2Recycle will engage new collection sites as soon as the plan is approved.

As mentioned previously, once the collection site requirements of the law are achieved,

Call2Recycle will shift to maintenance of the participating sites, with adjustments to outreach

efforts and tactics as the program evolves. Call2Recycle will work to continually improve the

program by working with DOEE staff to reassess accessibility metrics which may include a different

proximity performance goal that is more applicable for the District and an at-home mail back

program. In addition, Call2Recycle, along with DOEE staff, community stakeholders and possibly

other Stewardship organizations will explore options for improving (battery) collection in

communities that face environmental justice challenges associated with waste management.

Supplemental collection services will be evaluated for the District of Columbia in 2024. The

evaluation of any service will include metrics such as initial consumer participation with an

emphasis on underserved Wards, locations (for example zip codes) that show increased collection

rates, battery weights returned, overall cost of the program, among other factors.

22

New and existing collection locations will be accessible to District consumers via Call2Recycle's

online drop-off locator. C

all2Recycle's locator is updated daily so that only active collection sites

are presented. As part of Call2Recycle’s site outreach program Call2Recycle staff will conduct

quarterly outreach to each participating location to review the program and ensure continued

participation. Any sites that we are unable to reach after 3 attempts (in a given quarter) will be

inactivated and removed from the drop-off locator.

In addition, when Call2Recycle is provided advanced notice of a sites planned closing, Call2Recycle

will work with the on-site contacts to ensure that they have all the collection materials necessary

to recycle any remaining batteries and removal of the on-site signage. As indicated above,

Call2Recycle will conduct quarterly check-ins which in part will be used to ensure that any site

that was closed without our prior knowledge has been removed from our locator and listing of

actively participating sites on a daily basis.

D

. Roles and Responsibilities

T

he program plan is based on a shared responsibility model where all parties in the battery

journey have a role to play.

• S

orting and Recycling Contractors

All sorting and recycling contractors working under this plan will comply with all business licensing

and permitting requirements as well as any local, state, federal, and Provincial environmental

safety and transportation permits and regulations, such as but not limited to, recycling,

hazardous/universal waste management, storage, transportation and treatment, air quality,

water quality, import/export permits and any special conditions outlined in the licenses and/or

permits.

• District Government

Through its enforcement authority, the government is expected to enforce the Law as written.

• Consumer or End User

Consumers are responsible for safely recycling primary and rechargeable batteries and not

disposing of them in the waste stream.

• Collection Sites

Whether shipping batteries via boxes or drums, collection sites must complete training on safely

managing the collection container, including properly insulating terminals for specific primary and

rechargeable chemistries. In addition, sites should support efforts to promote the program and

how best to utilize it, based on guidance and material provided by Call2Recycle (Note: The training

materials are examples specific to Call2Recycle’s national take back program and are a reference.

Relevant safety materials will be updated to include mentions of all batteries.).

• Call2Recycle, Inc.

Call2Recycle will develop and administer an environmentally- and economically-sound program

focused on complying with the District's Law. Call2Recycle will utilize education, outreach, an

d

p

romotion to influence consumer behavior.

VII. RECYCLING OF BATTERIES: TRANSPORTERS, SORTERS & PROCESSORS

A. Citations

23

Statutory Citation

(5) A description of how the battery stewardship organization will arrange for components of the discarded

batteries to be recycled to the maximum extent economically and technically feasible, in a manner that is

environmentally sound and safe for waste management workers;

Regulatory Citation

(e) A description of how the BSO will arrange for components of the discarded batteries to be recycled to

the maximum extent economically and technically feasible, in a manner that is environmentally sound and

safe for waste management workers, including:

(1) The recycling process to be used for each type of battery chemistry that the BSO anticipates collecting;

(2) The criteria for how the BSO will evaluate the economic and technical feasibility of recycling the

components of discarded batteries, and the environmental and safety records of recycling facilities that will

be used to implement the plan;

(3) How the BSO applied the criteria in § 3902.1(e)(2) to select the recycling facilities;

(4) How the BSO will conduct any end-of-life handling, including management and disposal of batteries or

battery components that cannot be recycled, in accordance with applicable law; and

(5) A description of the periodic sorting that will be used to provide the estimate required by § 3903.3(e)(4);

B. Sorting Facilities

Primary and rechargeable batteries collected within the District will first travel to one of

Call2Recycle's approved sorting partners. The primary and rechargeable batteries will be weighed,

separated by battery chemistry, consolidated with similar types, and transported to a network of

qualified and approved battery processors.

C. Processing Standards & Due Diligence

Call2Recycle's downstream processors are selected through a fair and transparent process that

requires compliance with applicable environmental, health and safety, and transportation

regulations. Processors are expected to adhere to the standards of industry-recognized recycling

certification(s) and submit to audits by Call2Recycle or other external audit parties. Some

examples of potential vendor due diligence include:

• Annual desktop due-diligence compliance audits, including a review of OSHA Public Inspection

Records, EPA Enforcement and Compliance database and OSHA 300 and 300A logs.

• Review of the facility audit performed by CHWMEG (in the past two years) or an outside

auditor chosen by Call2Recycle to ensure the facility complies with all regulatory and

performance requirements. CHWMEG, Inc. is a non-profit trade association comprised of

manufacturing and other "industrial" companies interested in efficiently managing the waste

management aspects of their environmental stewardship programs. Their programs are

based upon their potential environmental liability related to the wastes that are inherently

generated by their companies' manufacturing processes.

• Written policies outlining corporate commitment to environmental management and

continuous improvement.

• Complete tracking and documentation of materials in and out of facilities

• Final destination receipt and disposal documentation/certification, downstream processing

material management, residual material management and residual waste management.

24

In an added effort to ensure the highest standards, the Call2Recycle program also undergoes

inspections to maintain industry-recognized certifications, like those listed below:

• Responsible Recycling (R2): "The R2 Standard provides a common set of criteria to recognize

responsible reuse and recycling practices, all along the used portion of the electronics

lifecycle. R2 Certification is the formal program for evaluating and monitoring businesses in

meeting the R2 Standard, protecting the environment, the health and safety of workers, and

communities, and positively impacting the movement toward a sustainable circular economy

while, enriching the lives of people all around the world." (SERI

https://sustainableelectronics.org/faqs/

)

• International Standardization Organization (ISO) 14001 "helps an organization achieve the

intended outcomes of its environmental management system, which provides value for the

environment, the organization itself and interested parties."

(ISO https://www.iso.org/standard/60857.html

)

• International Standardization Organization (ISO) 45001 "Specifies requirements for an

occupational health and safety (OH&S) management system, and gives guidance for its use,

to enable organizations to provide safe and healthy workplaces by preventing work-related

injury and ill health, as well as by proactively improving its OH&S performance."

(ISO https://www.iso.org/standard/63787.html

)

• Basel Action Network (BAN): Call2Recycle is the first battery collection and recycling program

to be recognized as an e-Steward Enterprise, by the Basel Action Network (BAN), for ensuring

the responsible downstream management of all toxic materials, no use of child, coerced, or

prison labor, and that toxic waste management must be done in accordance with best

available practices to protect workers and the environment.

• Audit Summaries: Call2Recycle continuously monitors and evaluates the efficiency and

quality of its downstream vendor's reclamation process and other potential primary battery

processors. All approved vendors must continue to meet Call2Recycle's rigorous guidelines

for sorting and processing. They are periodically required to submit to audits performed by

CHWMEG (a non-profit association which reviews commercial facilities that treat, store,

dispose, recycle, or transport waste). Routinely, the program arranges for audits of vendors

by major generators of primary and rechargeable batteries that want assurance that their

primary and rechargeable batteries are properly disposed. All consolidation, sorting, and

processing facilities are open to inspection and audit. Call2Recycle, Inc. may employ other

sorting facilities in the future as appropriate at its sole discretion. If any transporter or

processor (including sorter) is changed, in line with 20 DCMR 3902.6, Call2Recycle “shall notify

DOEE within thirty (30) days” of the change. Full audit summaries for approved sorters and/or

processors handling the District Program's in-scope batteries are available upon request.

• Call2Recycle R2 Certification: Call2Recycle receives Responsible Recycling (R2) certification

(Appendix D) from Sustainable Electronics Recycling International (SERI). SERI is the housing

body and ANSI-accredited (American National Standards Institute) Standards Development

Organization for the R2 Standard. SERI's mission is to create a world where electronics

products are reused and recycled in a way that promotes resource preservation; the well-

being of the natural environment; and the health and safety of workers and communities.

Downstream Vendor Selection Documents: Call2Recycle has the following downstream vendor

selection control policies that may be provided upon request:

• Downstream Vendor Selection Program (WORK7.01.01 Downstream Vendor & Carrier

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Selection Program)

• Downstream Vendor Questionnaire (FORM 07.01.01-R2 Downstream Vendor

Questionnaire), and R2 Desk Audit Checklist (FORM07.01.03-R2 DSV Audit Checklist).

Call2Recycle conducts due diligence on processors, per the SERI R2v3 standard. When considering

a company that has EPA violations, Call2Recycle follows its best practices to make informed

decisions. The organization begins by thoroughly understanding the nature and severity of the

violations and assessing the processor's response, including corrective actions and improvements

in compliance procedures. Call2Recycle reviews the processor's overall compliance history and

any past enforcement actions. Finally, the organization conducts a desktop audit to evaluate

whether any action should be taken regarding continued inclusion in the Call2Recycle processing

network. Downstream vendor selection and evaluation criteria include:

a. Evidence that Downstream Vendor adheres to a documented system to manage

environmental, health, and safety risks and legal requirements.

b. Evaluation of certifications including ISO 9001, ISO 45001, ISO 14001, RIOS and/or R2

c. Evidence that Downstream Vendor demonstrates knowledge of and has taken measures

to comply with all applicable environmental, health and safety legal requirements as

identified in its compliance plan.

d. Evidence that Downstream Vendor maintains a current list of its permits and copies of

each.

e. Evidence that Downstream Vendor conducts on a regular basis (e.g., as new types of

materials are processed, or new processes or equipment are used) a hazards

identification and assessment of occupational health and safety, and environmental risks

that exist or could reasonably be expected to develop at the facility.

f. Evidence that Downstream Vendor meets all applicable regulatory requirements to

receive material, and that use technology designed and operated to safely and effectively

manage the material.

g. Evaluation of EPA Environmental Compliance History Online (ECHO) Detailed Facility

Reports, Compliance Status and Findings.

h. Data sanitization and data security measures, as applicable for Downstream Vendors that

handle or receive data bearing devices.

• Solid or Hazardous Waste Registration or Permits: A list of all applicable solid or

hazardous waste permits is available upon request. The need for permitting is highly

dependent on the specific process each downstream vendor uses to process waste

primary and rechargeable batteries. As such, not all permits for all downstream vendors

will be the same.

It is important to note that some of the recycling processes for battery recycling produce non-

hazardous waste byproducts, namely non-hazardous, non-recyclable mixed solid waste plastics.

These materials are disposed of by Call2Recycle Downstream Vendors in accordance with

applicable state and federal law.

D. Primary Battery Processors

Below is a listing of all processors and their attributes used to process batteries generated in the

District. Below please find a description of each processor.

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(1) Non-lithium Processors

Processor

Address

Cirba Solutions Recovery

4930 Holtz Dr, Wixom, MI 48393

Cirba Solutions was selected as a processor for Call2Recycle based on the following qualifications:

• Recycling Efficiency Rate (RER): Cirba Solutions has a self-reported RER of 97.98%, which exceeds

INMETCO’s 85% RER. Cirba Solutions significantly exceeds the prevailing global standard of 50%,

as decreed by the European Union (EU). Even in Ontario, Canada, where the most stringent

standard of 80% is used, both facilities exceed it.

• Efficiency & Cost: With Cirba Solutions now providing both sorting and processing capabilities,

Call2Recycle can achieve greater cost savings and efficiency measures, as a result of not having to

transport these batteries several states away for final processing. In addition, Cirba Solutions

provides further efficiency as it is the only facility with optical sorting capabilities.

Batteries collected in the District will continue to be shipped directly to Cirba Solutions where

they will be recorded by site, sorted by chemistry, consolidated into truckload shipments, and

sent, if applicable, to Call2Recycle’s qualified processing network.

• Process Description: Non-lithium primary batteries will be processed by Cirba Solutions using a

room temperature, mechanical separation process where the battery components are separated

into three end products: 1) Zinc & Manganese concentrate; 2) Steel; 3) Paper, Plastic & Brass

Functions. These three end products are marketed and sold by Cirba Solutions to manufacturers

to be used as feedstock to make new materials. Most notably, Zinc and Manganese concentrate,

is combined with other materials to ultimately manufacture a granular fertilizer. Cirba Solutions

does not manufacture the final end product of granular fertilizer.

Processor

Address

International Metals

Reclamation Company

(INMETCO)

One INMETCO Drive,

Ellwood City, PA 16117

The International Metals Reclamation Company (INMETCO) utilizes a rotary hearth and an electric

arc furnace for thermal metal reclamation. INMETCO processes alkaline, carbon zinc batteries, as

well as nickel-based rechargeable batteries. INMETCO was selected as a processor for

Call2Recycle based on the following qualifications:

• Recycling Efficiency Rate (RER): INMETCO currently attains an 85% (using a “dry” process) RER,

which significantly exceeds the prevailing global standard of 50%, as decreed by the European

Union (EU). Even in Ontario, Canada, where the most stringent standard of 80% is used, INMETCO

exceeds it.

• Efficiency & Cost: INMETCO is the only primary battery processor which takes the zinc oxide

produced through thermal treatment and refines it into a variety of zinc uses, including as an input

into the manufacture of alkaline batteries. This “virtuous circle” to battery processing is unique.

In addition, INMETCO has historically been the most cost-effective option in North America,

balancing the cost of processing with its overall performance.

• Process Description: Non-lithium primary batteries will be processed by INMETCO at a high

temperature metals recovery ("HTMR") facility. HTMR is a process used to recover nickel,

chromium, and iron from metal bearing waste streams. Using an electric arc furnace melting

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process, impurities contained in the scrap metal are driven from the molten steel in the form of a

flue dust that is captured and controlled by emission control baghouses. When used for the

process of recycling non-lithium primary batteries, INMETCO recovers steel, brass and

manganese. Zinc is captured in baghouse dust. This material is then sent for further processing

where the zinc is captured and recovered.

(2) Lithium Processors

Processor

Address

Redwood Materials

2801 Lockheed Way

Carson City, NV 89706

Redwood Materials, Inc. (Redwood) operates a facility that reprocesses batteries into final

product and commodities. Redwood processes lithium primary as well as lithium ion and nickel

metal hydride rechargeable batteries. Redwood is an approved processor for Call2Recycle based

on the following qualifications:

• Recycling Efficiency Rate (RER): Redwood’s recycling efficiency rates consistently exceed the

prevailing global standard of 50%, as decreed by the European Union (EU).

• Efficiency and Sustainability: Redwood Materials, Inc. (Redwood) operates a facility to process

batteries and electronics scrap into commodities. Redwood receives, refines and treats material

using a hybrid process combing heat treating and hydrometallurgical processing. Using

proprietary technology, they are able to recover metals from electronics and batteries including

nickel, copper, cobalt, lithium, as well as lead, tin, iron, aluminum, silver and gold. The lithium

main product outputs of the battery process are high-purity nickel and cobalt shot, lithium

concentrate and alloy ingots. Redwood is the only battery recycler operating at commercial scale

in the United States to employ hydrometallurgical processing for lithium-based batteries.

• Process Description: Lithium primary batteries are processed at Redwood Materials using a

multi-step process. Batteries are thermally pre-processed in an oxygen starved environment for

discharging and electrolyte capture. It is important to note that this process is energy-neutral and

not the same as high-temperature smelting processes used in pyrometallurgy. Discharged

batteries are then size reduced via shredding. Steel battery casings are mechanically separated.

The remaining material, including lithium, zinc and manganese can then be subject to

hydrometallurgical metal separation capabilities that Redwood is actively developing.

Processor

Address

Cirba Solutions

9384 BC-22A,

Trail, BC V1R 4W6, Canada

Cirba Solutions, located in Trail, British Columbia, Canada, has been a leader in battery recycling

and management for 25 years, including client services, research and development,

environmental compliance, and recycling best practices. Cirba Solutions is one of two battery

recycling processors in North America who actively accepts lithium primary batteries for recycling

and materials recovery. The addition of Cirba Solutions as a processor for Call2Recycle was based

on the following qualifications:

• Recycling Efficiency Rate (RER): Cirba Solutions has a self-reported RER of 56.4%, which exceeds

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the prevailing global standard of 50%, as decreed by the European Union (EU).

• Efficiency & Cost: With Cirba Solutions being located in North America, utilizing them as a

processor for lithium primary batteries, Call2Recycle is able to achieve greater cost savings and

efficiency measures, as a result of not having to transport these batteries to additional approved

processors.

• Process Description: Lithium primary batteries processed by Cirba Solutions use a multi-step

process. Prior to processing, the packaging is removed, and the batteries are weighed and placed

into liquid nitrogen. This cools the batteries thus minimizing the reactivity of the batteries during

shredding and treatment. Gases or fumes liberated during shredding are controlled in a wet

scrubber system and a travelling bed filter. Atmospheric emissions are monitored to ensure

compliance. Soluble components of the battery that are dissolved in the solution are precipitated

from solution and recovered and processed to produce lithium carbonate. Scrap metal and plastic

from the batteries is also recovered from the treatment tank. The scrap is separated into metallic

and non-metallic fractions and are used as feedstock to produce new materials.

E. Rechargeable Battery Processors

To optimize efficiency, reclaim the maximum amount of material for secondary use, and to ensure

processors have the capacity to handle batteries sent to them, Call2Recycle has built a global

network of world-class processors. Below is a listing of rechargeable battery processors,

organized by the chemistry they process.

(1) Lithium Ion (Li-Ion) Processors

Processor

Address

Recycling Coordinators, Inc.

(RCI)

600 E. Exchange St.

Akron, OH 44306

Recycling Coordinators Inc., (RCI), located in Akron Ohio, processes all types of metal bearing by-

products that contain concentrations of nickel, cobalt, copper, chrome, molybdenum, tungsten

and titanium. Through full product stewardship, Recycling Coordinators will wholly consume each

industrial by-product to maximize an environmental outcome. RCI was selected as a processor for

Call2Recycle based on the following qualifications:

• Recycling Efficiency Rate (RER): RCI’s recycling efficiency rates consistently exceed the prevailing

global standard of 50%, as decreed by the European Union (EU).

• Efficiency & Flexibility: RCI is located in northeast Ohio, in close proximity to major US population

centers and to one of Call2Recycle’s primary sorting partners (Cirba Solutions) in Wixom, MI,

reducing the environmental impact of transporting batteries from sorter to processor.

Additionally, RCI is able to process both lithium-ion and Ni-MH batteries.

• Process Description: Lithium-ion batteries will be processed by RCI using a room temperature,

mechanical separation process where the battery components are separated into three end

products: 1) Black mass, containing nickel, cobalt, manganese, lithium, and graphite, 2) steel, and

3) mixed Aluminum Copper and plastics. The three end products are used as feedstock to produce

new materials.

Processor

Address

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Li-Cycle

1669 Lake Avenue, Building 350

Eastman Business Park

Rochester, NY 14615

Li-Cycle is a clean technology company with technology for resource recovery of end-of-life

lithium-ion batteries. Li-Cycle Technology™ is a closed loop, economically viable, safe and

sustainable process that can recover 80 – 100% of all materials in lithium-ion batteries. Li-Cycle‘s

mission is to provide sustainable and safe customer-centric solutions for end-of-lifecycle lithium

ion batteries while meeting the rapidly growing demand for critical battery material. Li-Cycle was

selected as a processor for Call2Recycle based on the following qualifications:

• Recycling Efficiency Rate (RER): Li-Cycle’s recycling efficiency rates consistently exceed the

prevailing global standard of 50%, as decreed by the European Union (EU).

• Efficiency & Flexibility: Li-Cycle is located in upstate New York, in close proximity to major US

population centers. Additionally, Li-Cycle has spokes in Gilbert, AZ and North Port, AL; these

facilities will not receive District batteries, but Li-Cycle’s multi-facility footprint offers Call2Recycle

the ability to minimize program-wide environmental impact. Li-Cycle is also currently developing

hydrometallurgical metal recovery capability at their Hub in Rochester, NY.

• Process Description: Lithium-ion batteries will be processed by Li-Cycle using a room

temperature, mechanical separation process where the battery components are separated into

four end products: 1) Separator plastic; 2) Aluminum and Copper from cathode and anode foil; 3)

black mass, containing nickel, cobalt, manganese, lithium, and graphite, and 4) steel. The four

end products are then sent to downstream processors for further refinement and separation.

Processor

Address

Interco

10 Fox Industrial Dr.

Madison, IL 62060

Interco was selected as a processor for Call2Recycle based on the following qualifications:

• Recycling Efficiency Rate (RER): Interco’s recycling efficiency rates consistently exceed the

prevailing global standard of 50%, as decreed by the European Union (EU).

• Efficiency & Flexibility: Interco is centrally located in Maddison, IL, in close proximity to major US

population centers. Additionally, Interco is able to process both lithium-ion and Ni-MH batteries.

Interco is also currently developing hydrometallurgical metal recovery capability at a facility in

Fredericktown, MO.

• Process Description: Lithium-ion batteries will be processed by Interco using a room temperature,

mechanical separation process where the battery components are separated into four end

products: 1) Separator plastic; 2) Aluminum and Copper from cathode and anode foil; 3) black

mass, containing nickel, cobalt, manganese, lithium and graphite, and 4) steel. The four end

products are then sent to downstream processors for further refinement and separation.

Processor

Address

Redwood Materials

2401 Conestoga Drive

Carson City, NV 89706

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Redwood Materials, Inc. (Redwood) operates a facility that reprocesses batteries into final

product and commodities. Redwood processes lithium-ion rechargeable batteries. Redwood is an

approved processor for Call2Recycle based on the following qualifications: