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The growth of electric vehicle (EV) sales is expected to accelerate in the coming years, and with it the volume of batteries reaching their end of life (EoL) will also significantly increase. This poses several questions and challenges for stakeholders across the battery supply chain, from battery cell manufacturers to Original Equipment Manufacturers (OEM), as well as battery recycling businesses and battery reinstallers. For example, if an OEM sells a battery for reuse (either at whole-battery or component level) to a reinstaller, then is it the OEM’s or the reinstaller’s liability, according to current regulations? Does current legislation allow for a battery at the end of its original use to be classified as something other than waste? What impact does this have on the entire journey of a battery at its end of life?
UK legislation defines the producer of an industrial battery as the person “who puts the batteries on the market in the UK for the first time” and this could be a manufacturer or an importer. This whitepaper investigates producer responsibility in the context of the reuse of EV batteries. More specifically, it addresses how an EV battery reinstaller can approach EV battery teardown and reuse at scale. The whitepaper explores the entire end of life journey of an EV battery, investigates the legislation surrounding an EoL battery’s classification as waste, as well as implications to their transportation, while also providing perspectives from stakeholders and analysing ways to transfer producer responsibility at the EV battery’s end of life.
The key findings of the whitepaper are as follows:
1. At the time of writing, the volumes of genuine EoL EV batteries are relatively low. Therefore, the EoL market opportunity is not yet profitable for OEMs, be it vehicle or battery manufacturers.
2. The current regulations surrounding EoL battery processing were made with recycling in mind, the various reuse opportunities which could be possible have not yet been taken into consideration. This outdated regulatory framework thus acts as a barrier to enabling innovative EoL business models to emerge within industry.
3. At the present time, the regulations do not advocate the transferrance of liability away from the original battery producer towards the new owner. This is coupled with a lack of transparency surrounding the accurate classification of waste types. Both issues act as barriers to enabling progressive methods of battery reuse at EoL.
4. Additionally, there is a lack of precedence for operators applying new methods of battery reuse at scale whilst operating within the current regulatory framework.
5. The regulatory framework has created an environment where boundaries are often unclear. It is imperative that operators within this environment ensure they clearly interpret and understand their responsibilities to the best possible effect. Operators also need to ensure they stay abreast of any potential updates to legislation and classification standards in the future.
In the short term, these findings pose a significant liability challenge for both OEMs and those seeking second life opportunities. The likely consequence is that OEMs will opt for a low-risk strategy and second life opportunities will be missed. In the longer term, a reformation of current regulations to allow transference of liability would support the transition and growth of reuse opportunities for second life battery operators, as the regulatory focus currently is centred around recycling only.
There is an opportunity in the long term where a reinstaller can position themselves as a proven, compliant operator which is capable of receiving and processing significant volumes of batteries for reuse from OEMs. This would be dependent on regulators specifying and clarifying the liability of each partner in a reuse scenario for their operations to be feasibile. It is suggested that any reuse operator keep up to date on emerging legislation and regulation from the Department of Environment, Food and Rural Affairs (DEFRA), as well as the European Commission.
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