11 January 2024
1.2024 - WHAT'S IN STORE FOR THE AUSTRALIAN BATTERY RECYCLING INDUSTRY
Happy new year and best wishes for a prosperous 2024.
This year is shaping up as another momentous one for the battery recycling industry. ABRI is watching the following key trends and is providing expert advice and assistance to members and governments to successfully navigate the structural change underway:
increased investment in lithium battery recycling infrastructure and ongoing technology innovation across Australia. Investment support for industry to be ready at scale and take advantage of export opportunities is a high ABRI priority as well as navigating planning and environmental approval frameworks. This is not a simple issue, however, in particular complicated by any need for international equipment acquisition which is falling foul of highly dislocated international shipping movements (Red Sea/Suez Canal & Panama Canal issues as examples).
Mounting interest from international investors in Australian battery recycling technology and investment opportunities. ABRI will continue to provide introductions to Australian battery recycling members and has also arranged with the Export Council of Australia a roundtable in February to focus on European, Middle East and Southeast Asia export and investment opportunities. This request is timely as one are the ABRI Executive Leadership has been considering is enhanced co-operation between ABRI and similar peak body international organisations.
Growing OEM and corporate requests for Australian battery recycling services and for evidence that batteries have been recycled at end of life (i.e. tracking). This is happening across all battery chemistries and Australia is here simply falling in line with global trends.
Government action is accelerating to support safe household handling of consumer batteries and reduce fires at waste facilities due to incorrect battery disposal. Environment Ministers asked the Queensland Government to lead national work on the waste facility fire issue. To support this work, ABRI is engaging with Queensland Government officials and other jurisdictions, as well as key stakeholders.
Insurance industry involvement in battery safety and recycling policy is increasing and ABRI is engaging with the Insurance Council of Australia to see how industry can work together to develop solutions to insurance challenges. Unusually, the industry has been active in issuing press releases on the topic in the lead up to Christmas – the largest gift giving and waste period of the year. Insurance Council of Australia is focusing on safe escooter and ebike handling and Zurich Insurance highlighted the need for safe disposal of embedded batteries in toys in order to prevent waste facility fires. In the UK, a staggering 9 million toys are estimated to be sent to landfill over the Christmas period.
Small lithium batteries will dominate the wastestream for the next few years. However, rapid growth in EVs and BESS (thousands of percent a year) batteries coming through for recycling will see their market share in lithium waste management needs rise from a negligible amount to 30% of the lithium battery recycling market by 2034/35. The policy levers required to manage reverse logistics for these segments will need to be fit for purpose and may require variations to address the needs of the different battery sectors.
The 2024 Australian Battery Manufacturing and Recycling Summit will again provide an opportunity for ABRI members to hear from experts and discuss industry challenges and solutions. ABRI is currently organising sponsorship and speaker slots and further details will be provided during Q1. Members interested in sponsoring should reach out to ABRI CEO, Katharine Hole. Building on the overwhelming success of the first year’s Summit the second year will provide even richer content for participants. ABRI financial members will also be provided with a significant discount for their attendance – with discounts aligned with level of membership.
The 2024 ABRI Events Calendar, a now regular segment of ABRI member bulletins and has details on the above and other member events. The calendar is launching with a landmark information and networking session – the JWS sponsored invitation to hear from their experts on legal developments in waste/circular economy and insights into funding/investment structuring. This will be followed by networking drinks.
This builds on a successful 2023 which saw ABRI’s membership reach 60, significantly increased media coverage, government and other stakeholders specifically seeking out ABRI advice and insights, and the inaugural Australian Battery Manufacturing and Recycling Summit.
We look forward to continuing to engage with the ABRI membership over 2024. Please reach out to ABRI President, Nicholas Assef, or ABRI CEO, Katharine Hole, at anytime to discuss issues and opportunities as both are keen to propel ABRI to great success across 2024 / 2025.
All the best
Nicholas Assef, ABRI President, & Katharine Hole, ABRI Chief Executive Officer
2. REMINDER - RSVP FOR JOHNSON WINTER SLATTERY/ABRI MELBOURNE (7 FEB) WASTE REGULATION + INSIGHTS ON FUNDING INFORMATION SESSION AND NETWORKING EVENT
REGISTER HERE
3. NSW - WASTE BATTERY TRACKING
The new NSW EPA waste tracking system is due to commence in February 2024. As part of a separate process, the NSW EPA is reviewing rules around tracking used batteries particularly in light of lithium battery fires.
ABRI has been provided by the following advice from the EPA’s Regulatory Practice & Service area:
The EPA has previously issued exemptions from waste tracking requirements under the Protection of the Environment Operations (Waste) Regulation 2014 for:
Spent lead acid battery waste [2009 see page 5320]; and
Waste batteries destined for reuse [2006 see page 10295].
These exemptions were issued many years ago and need to be revised to meet current circumstances. Recent fire incidents involving waste lithium ion batteries have highlighted a need for the EPA to look more closely into their management, which includes tracking their movements.
As discussed [with ABRI in mid December 2023], the EPA intends to work with the battery industry to determine if and how different types of waste batteries should be tracked.
In the interim and before we make a clear decision, the EPA will treat the two battery exemptions as still being in force. If you were not required to track the movement of a load of waste batteries under the previous exemptions, you do not need to do so. The EPA will consult with industry in the New Year [2024] to before finalising our position.
4. VICTORIA - COMMENCEMENT OF REQUIREMENTS FOR MANAGING RISK TO SERVICE INTERRUPTIONS ACROSS THE BATTERY RECYCLING VALUE CHAIN
The final (as made) Circular Economy (Waste Reduction and Recycling) (Risk, Consequence and Contingency Plans and Other Matters) Regulations 2023 (the Regulations) are now available and came into operation on 20 December 2023.
In Victoria, these Regulations will impact all businesses in the battery recycling chain (regardless of chemistry) as the legislation’s objectives include focus on introduction of a circular economy in Victoria and service standards. Battery recycling is defined as an essential service and one of the priorities is minimising disruption to services. Battery recyclers should consider how they manage service disruption and also whether they are a responsible entity (section 6 of the Regulation). If you consider you are a responsible entity, you have 60 days from 1 February to notify Recycling Victoria of your designation.
Recycling Victoria has advised ABRI that the Regulations support the implementation of the risk, consequence and contingency framework, established under the Circular Economy (Waste Reduction and Recycling) Act 2021. The framework helps manage significant risks of failure, disruption or hinderance to essential services in the waste, recycling and resource recovery sector.
In particular, the Regulations:
Prescribe ‘essential waste, recycling or resource recovery services’ [including batteries]
Define ‘responsible entities’ that must have a Responsible Entity Risk, Consequence and Contingency Plan (RERCC Plan)
Prescribe requirements for the preparation and content of the Circular Economy Risk, Consequence and Contingency Plan (CERCC Plan)
Prescribe content of RERCC Plans and offences related to RERCC Plan requirements
Prescribe the form and fees for exemption applications
Provide for a waiver of exemption application fees by the Head, Recycling Victoria.
After the inaugural CERCC Plan is released by Recycling Victoria and published on their website (currently planned for early 2024), entities who provide an essential service will have 60 days to self-identify as responsible entities based on the criteria prescribed in the Regulations.
Recycling Victoria has advised it will shortly provide guidance to help responsible entities comply with the obligations in the Circular Economy Act and the Regulations. [ABRI will forward any advice it receives.] This information will also guide responsible entities in developing their own RERCC Plans in the coming years, with the first of these due to be submitted to the Head, Recycling Victoria by September 2024. It is expected that this guidance material will be available soon after the publication of the inaugural CERCC Plan.
ABRI provided a submission to the draft regulations and the Victorian Government’s response to the submissions is here. Please reach out to ABRI CEO, Katharine Hole, if you require any assistance.
5. CALENDAR OF ABRI MEMBER EVENTS
ABRI Event Calendar
7 Feb (4-6pm AEDT) – Melbourne sponsored by ABRI member Johnson Winter Slattery a full service law firm with presentations on legal developments in the areas of waste and circular economy + insights on funding and structuring investments followed by networking drinks Invitation & Registration
NEW – 15 Feb – online (2-3pm AEDT) Australian Automotive Aftermarket Association (AAAA) presentation on key insights into the automotive workshop industries’ preparation for EV transition. Registration
NEW – 21 Feb – online (3-4pm AEDT) Export Council of Australia web based roundtable to explore ABRI member needs on ways to promote the Australian battery recycling industry to investment partners in the Europe, the Middle East and Southeast Asia. Opportunities include the establishment of a consortium for research and commercialisation, and direct investment into individual Australian businesses. Registration
NEW – 14 Mar – online (2-3pm AEDT) 2024 ABRI Annual General Meeting. Registration
15 Aug Sydney – 2024 ABRI Battery Recycling & Manufacturing Summit
6. ABRI MEDIA RELEASES, SUBMISSIONS AND PRESENTATIONS
Upcoming Submissions
Due 31 January 2024 – NSW Regional Development priorities with ABRI to focus on links between clean energy investment and battery recycling
TBC – options for tracking waste lithium battery movements under hazardous waste frameworks