The Battery Directive consultation came to a close last November and EGARA wanted to respond for a number of reasons.
Most importantly becoming a stakeholder, meaning that the association will be invited to consultation meetings and working groups. Another reason is that they will have their interests noted at the European Commission (EC).
Here’s what the association discussed at their meeting:
What is going on with batteries and their Directive? In short: technological developments have gone faster than legislation can keep up with. So with regards to lithium-ion batteries from hybrids/electrical vehicles (H/EV), the Directive has become obsolete. Traction batteries for H/EV are lithium-ion and even starter batteries are no longer lead-acid, but lithium-ion in some models.
The battery Directive has some goals, such as, banning or reducing hazardous materials in batteries, producer responsibility and reporting about recycling. Also some directions for facilities are mentioned in the annexes, like the better known End-of-Life vehicle (ELV) Directive does. But for lithium-ion batteries, nothing is taken care of.
Flammability of the electrolyte was also mentioned. The association can take care of these batteries, with an inexpensive simple application, for example: the current Directive dictates containers, while for lithium-ion batteries this is counterproductive in case of fire.
Extended Product Responsibility (EPR) is another matter. For lead-acid batteries, the last owner can have them collected without costs for the take-back. For industrial and traction batteries, it’s unclear. The problem is, lead-acid batteries always have a positive value. Even if the EC wants lead to be phased out, it is in fact the lead that makes them a perfect example of a circular economy product. Lithium-ion is a different case. Broken cells only cost money to have them recycled. If they need to be paid for to have them recycled (or even accepted), it’s not really an incentive to have them end in the right places.
Another thing about EPR is going on. As long batteries can be reused, they can be sold. No problem if ownership isn’t preventing anyone from doing so. If batteries get under 80% capacity, they are no longer fit to function as traction batteries, but they can be recycled for energy storage for companies or households. The functioning cells are used for new devices. If it’s no longer a car battery, there’s still value in the old batteries. The recycler, however, becomes a producer from this moment and EPR is the new producer’s responsibility. The high recycling costs come when these devices reach the end of life phase. They are just postponed with their second life as an energy storage device. On the other hand, the older EV’s get, the more cells from a traction battery is needed to be recycled under the producers EPR.
EGARA made the following points to the consultation:
- They have the facilities to take care of H/EV’s;
- They can distinguish functioning batteries from batteries that need to be recycled;
- They can dismantle them from the vehicle and store them for collection and recycling;
- Any directions need to be dynamic;
- Producers should not be able to simply avoid EPR or tranship costs to others.
To find out more about the battery Directive click here www.ec.europa.eu