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Discussions with the Industry: Defining Battery Second Life Opportunities and Exploring Legislative Improvements

Project VALUABLE, led by HSSMI, has been instrumental in shedding light on second-life opportunities for li-ion batteries. As the project closed at the end of March, we are now sharing our findings in order to generate discussion amongst the public and, in particular, those who are looking to continue the research that VALUABLE began. In this blog series, we will be discussing a different battery-related topic each time – from testing and legislation to end of life, recycling and remanufacturing. This time, we take a look at legislation and compliance.


Discussions with the Industry: Defining Battery Second Life Opportunities and Exploring Legislative Improvements feat
Image: © Tierney / Adobe Stock

For both newcomers to the industry and established companies, there is an extensive list of definitions that need to be understood before diving into legislation around battery end of life and waste management. VALUABLE comprehensively contributed to clarifying the terms through discussions within the consortium, as well as with industry representatives in its Industrial Advisory Board, which included automakers, recyclers, dismantlers, powertrain component suppliers, and prominent research institutions. These discussions also helped stakeholders that were not directly involved in VALUABLE, such as the British Standards Institute (BSI) and the Global Battery Alliance.

A Circular Supply Chain for Automotive Traction Batteries

Based on outcomes of discussions in the VALUABLE Industrial Advisory Board, HSSMI designed a flow diagram to illustrate the envisioned circular supply chain for automotive traction batteries. Depending on the battery condition, the diagram highlights the optimal usage of the battery to maximise the value extracted from it. Typically, a battery will end its first life because it is due for service, damaged, or its State of Health (SoH) is compromised to the extent that it is no longer of use in automotive applications. The flow diagram was refined in the Battery Technology team at HSSMI and incorporated into the HSSMI report “End of Life Strategies for Electric Vehicle Li-Ion Batteries” [1].

Discussions with the Industry: Defining Battery Second Life Opportunities and Exploring Legislative Improvements pClarifying Terms and Definitions with the Industry

The mainstream definition for “remanufacturing” was brought up several times by industry representatives in the VALUABLE Industrial Advisory Board, and questions of how electro-chemical devices such as batteries can meet these requirements were raised. As battery chemistries evolve over time, modules and cells could be replaced by better ones, leading to increased performance as a result of the remanufacturing process. It was questioned whether this practice of replacing modules and cells would still meet the standard definition of “remanufacturing”[2] or the mainstream definition of “remanufacturing” would not be accurate for batteries. The interchangeable use of the terms “recondition” and “refurbish” was also discussed and how these were possibly more suitable for an ”as new” product than for a product in an “acceptable state”. It was ultimately agreed that remanufactured batteries should meet the OEMs warranty, but could not be characterised as brought back to an “as new” state due to the current inability to reverse the degradation of modules and cells.

HSSMI, as lead partner in VALUABLE, later shared the outcomes of this discussion and many similar ones with the Global Battery Alliance and the British Standards Institute (BSI). In particular, HSSMI helped draft the recent BSI’s PAS7060 Electric Vehicles – Safe and environmentally-conscious design and use of batteries – Guide[3], which provides guidance on vehicle design, battery integration and battery use for electric and hybrid electric vehicles and aims to optimise battery recycling and re-use.

Establishing a Strong UK Legislative Framework for Automotive Traction Batteries

There are several regulations related to battery waste management in the UK, however, the current targets are not sufficient to encourage widespread automotive traction battery recycling. Given the anticipated increase in electric vehicles in the coming years, it is important to give proper consideration to the management of automotive traction batteries at their end of life now.

The Environment Agency and the Department for Environment, Food & Rural Affairs (DEFRA) are continuously working to improve the legislation. One of the documents currently being discussed is the recently announced European Commission proposal for a new Regulation on Batteries and Waste Batteries. It includes both lessons for a legal framework on battery second life opportunities and will also be important in the future for any OEM or cell manufacturer wanting to do business with the EU.

Moreover, the British Standards Institution (BSI) has been working to draft a landscape document for automotive traction battery design, manufacture, safety, and testing[4], which provides some much-needed guidance for both industry and government.

Looking further afield for good examples, it is worth looking at the Chinese coding legislation – arguably one of the most stringent regulations in this sector. Although it is relevant only to the Chinese market, it obliges OEMs to provide a substantial amount of data, enabling the tracking of battery materials throughout their lifetime. It remains to be seen what approach the UK will take in developing legislation on automotive traction battery waste management and what information therefore will be required from OEMs, dismantlers and scrap yards.

HSSMI, with its experienced Battery Technology team, is involved in steering groups that aim to facilitate the sustainability of batteries and has been working with DEFRA, the Environment Agency, and the Faraday Battery Challenge to improve legislation for automotive traction batteries. This is ongoing work and HSSMI would welcome thoughts, concerns, or questions from across the battery supply chain on existing legislation and requirements for further regulation.

The information contained in this article has been generated through discussions in the project VALUABLE Industrial Advisory Board.

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Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

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