The Partnership for Responsible Battery and Metal Recycling (ProBaMet) Project starts in Nigeria with visits to lead smelters in Ogun State

In spring 2024, members of the ProBaMet[1] project undertook a working week in Nigeria with the purpose of holding an inception workshop with local stakeholders and visiting Used Lead-Acid Battery (ULAB) recycling plants in and around Ogun[2] and Lagos States in the Federal Republic. The ProBaMet project aims to support the upgrading of the recycling sector through three intervention levels:

1. providing training on environmental health and safety to recycling facilities;
2. introducing incentives to bring about facility improvements by supporting Nigerian regulatory authorities in their enforcement; and
3. creating business opportunities for high-standard recycling through a coalition of solar companies looking for responsible battery disposal solutions and international companies sourcing secondary raw materials from approved facilities.

Building trust & facilitating knowledge transfer among participants

We held an inception workshop in Ogun State to mark the start of the project in Nigeria. Email exchanges and brief meetings had already taken place virtually in the past two months. The inception workshop served as an opportunity to sensitize ULAB recyclers, local authorities and regulators on current and upcoming German and EU legislation that would require improved due diligence in the supply chain if the European secondary raw materials market is to remain open to Nigeria. Given that secondary lead from Nigeria is known to make its way to USA, Turkey and South Korea, it is not inconceivable that products made from this lead find their way into the European market. Beyond these project-specific needs, the workshop was the first in-person meeting between the ProBaMet `International´ team and local stakeholders in Nigeria. Hence, it also served as an opportunity to build trust between partners and to plan initial facility assessments for the working week ahead. Present at the workshop and on visits to lead smelters in Ogun State were representatives from the Nigerian Federal Ministry for Environment, Nigerian National Environmental Standards and Regulations Enforcement Agency (NESREA), Lagos State Ministry for Environment and Water Resources, Ogun State Environmental Protection Agency, Alliance for Responsible Battery Recycling, Community leaders such as the Oba of Ogijo and representatives of GIZ Nigeria.

Nigerian regulators commit to enforcement measures in the ULAB recycling sector

At the inception workshop, federal actors, notably from NESREA, resolved to work with the project in the development of minimum standards, joint inspections of facilities and improvement plans and to ensure sanctions on the most polluting ULAB recycling facilities. These commitments represent the “push factors” that the project needs from local stakeholders to incentivize recyclers to engage with the project and commit to improvement plans. Local community leaders present at the workshop highlighted the impact of environmentally unsound ULAB recycling in their communities and welcomed interventions to improve the sector. This agitation also puts further pressure on recyclers to improve their operations and avoid potential legal challenges from lead emissions.

The initial assessment of ULAB recycling facilities was conducted over three days and provided an understanding of which facilities, with some effort, could be recommended to the coalition of solar companies looking for responsible battery disposal solutions and international companies sourcing secondary raw materials. These serve as “pull factors” to ULAB recyclers in Nigeria hoping to have better access to ULABs and potentially enter into direct commitments with EU off-takers for refined lead. The ProBaMet team together with local stakeholders and regulators visited and assessed a total of six plants in Ogun State, Nigeria.

Joint ULAB recycling plant assessments

Five of the six assessed plants showed severe weaknesses in various technical and operational aspects of ULAB recycling and lead smelting. While all plants make use of rotary furnaces that are connected to baghouse filter plants, a large number of other aspects are of concern and are in a state whereby the emission of hazardous lead dust into the workplace and the environment is inevitable. Areas of concern have been identified and discussed with plant managers and authorities and are documented in assessment reports tied to suggestions for remediation and improvement plans. Concerns are linked to both, the technical set-up and operation of the plants, as well as management practices and health and safety monitoring. Summing up, conditions in these five plants are clearly substandard with a very high likelihood of exposing the majority of workers and local residents to irresponsible high lead concentrations.

On the brighter side, one of the visited plants was remarkably different: it has plant set-ups and operations that are in-line with best practices in many aspects. Standards are simply much higher compared to all other plants visited.

Outlook: further regulatory efforts required to ensure the survival of compliant recyclers

In general, the existence and operation of heavily polluting plants effectively shapes the Nigerian market in a way that higher-standard plants have little room to operate (due to their higher costs and less financial ability to acquire ULABs for recycling compared to the premiums offered by more profitable polluting plants). Subsequently, stringent regulatory efforts are needed to bring such low-standard competition to an end. The exemplary recycling plant referred to in the paragraph above is currently not operating at its required capacity due to a lack of batteries. Given their higher operational costs, they are simply unable to pay the premiums offered to battery collectors by other recyclers who generate a higher profit due to their externalization of environmental costs.

The working week and facility assessment visits can be summed up in a statement from the former Director General of the Nigerian National Environmental Standards and Regulations Enforcement Agency (NESREA), Prof. Aliyu Jauro. He said: “Nigeria wants and needs lead recycling facilities. However, this need for lead recycling must be balanced with the protection of workers and local communities where facilities are located. NESREA will not relent in enforcement measures and will work with ULAB facility managers to steadily improve standards in the industry.”

The author of this post is Frederick Adjei, a researcher in the Sustainable Products & Material Flows division of Oeko-Institut in Berlin.