I have a question regarding the type of recovery and disposal information
that should be provided for rechargable batteries.  

At this time I am specifically concerned with nickel-metal hydride (Ni-mh)
rechargeable batteries and what type of information needs to be
provided to the user?  I understand that Ni-mh batteries are not as much
of a concern as some other types of batteries (Ni-Cad for example), and
I have been told that it is O.K. to just dispose of Ni-mh batteries in the
regular trash.  However, I don't know if I buy into this since nickel is still
considered a heavy metal.

Some Ni-mh batteries I have seen contain all, some, or none of the
following elements on the label.  - - Recycle arrows, X'ed out trash can
icon, and "dispose of properly" statement.  There doesn't seem to be a lot
of consistency in labeling.

Questions:
(1) It has been suggested that we don't put the recycle arrows, the X'ed
out trash can, or the "dispose of properly" statement on our battery label.
Not having these elements would imply that it is O.K. to just throw the
batteries in the household trash.  Is this acceptable?
(2) On the opposite side, if there is indeed no recycle program and we
still state that the batteries must be disposed of properly and not thrown
in the regular trash, what is the user supposed to do with his or her
spent batteries?
(3) In this case, what does "dispose of properly" mean?
(4) Is the manufacturer obligated to accept back spent batteries?
(5) Is it incorrect to have the recycle arrows on Ni-mh batteries?
(6) What's everyone else doing?  There are a lot of Ni-mh rechargeable
batteries out there so I hope others have some useful information.

My understanding of the battery directive is that it only applies to
batteries which contain one of the following:
- more than 25mg mercury per cell
- 0.025% cadmium by weight
- 0.4% lead by weight

Thanks in advance for any information.

Craig Hensley
Compliance Engineer
Iomega Corp.
Roy, UT
801-778-4135

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