5 May 2023
1. HOLD THE DATE – 31 AUGUST 2023, SYDNEY – ABRI’S FIRST BATTERY RECYCLING CONFERENCE
ABRI will be holding its first conference on 31 August in Sydney. Further details will be forthcoming in the next few weeks. In the interim, hold the date so you don’t miss out in joining fellow ABRI members and the broader battery recycling industry to promote and support a rapidly growing industry.
The conference will focus on Australia’s battery recycling industry and how it:
Drives innovation and best practice
Delivers a circular economy, critical minerals security and net zero emissions
2. APPLYING TO VIC EPA FOR A11 PERMITS TO TRANSPORT ULAB FOR RECYCLING INTO VICTORIA FROM ANOTHER STATE OR TERRITORY
In consultation with the Vic EPA, ABRI has prepared the following information on applying for A11 permits to transport hazardous waste into Victoria for recycling.
The Vic EPA takes into account a number of factors when it reviews an A11 application and makes a decision to issue (or not issue) an A11 permission. The factors cover both general principles which are considered in every decision the regulator makes and specific (prescribed) requirements applicable to the permission (e.g. A11) being issued. The two are interlinked as the general principles will influence how the prescribed requirements are assessed.
Chapter 2 of the Environment Protection Act 2017 sets out the environment protection principles which the EPA should give regard when administering the Act e.g. issuing permits. Regulation 28(c) of the Environment Protection Regulation 2021 sets out the matters the EPA must take into account when determining whether to issue an A11 permit including “is an appropriate receiving/treatment facility for the proposed wastes in State or Territory where the waste was generated.” The EPA publishes guidance on applying for an A11 licence and guidance on applying the environment protection principles.
What does this mean for companies seeking to transport ULAB from another state to Victoria?
When preparing an A11 permit application consider how the proposed transport of ULAB will address both the general environmental principles and specific A11 requirements. Factors to take into consideration to justify why the waste needs to be brought into Victoria could include:
Greenhouse gas impacts across the product life cycle
Resource recovery and circular economy outcomes across the product life cycle
Economic and commercial implications, both broader industry impacts and individual company impacts
Information on the environmental performance of the Victorian facility
When preparing an application for an A11 permit, please check in with the Vic EPA before submitting. The key contact is Julia Gaitan, Team Leader Permitting, Permissioning to seek further guidance. Julia can be contacted via email on Julia.Gaitan@epa.vic.gov.au or phone 03 8458 2311.
If ABRI members experience further issues with interstate ULAB transport, please email ABRI CEO Katharine Hole so she can monitor industry impacts and work with regulators as needed.
3. WELCOME TO NEW MEMBER - LOTE CONSULTING
ABRI welcomes Lote Consulting as an affiliate member. Lote Consulting is an Australian engineering company specialising in fire safety, security, and cybersecurity.
Of relevance to the battery recycling industry, Lote provides services in fire engineering design, dangerous goods, passive fire systems, assistance responding to fire safety orders, risk assessment and emergency management. Additionally, Lote provides expert security consultancy services for the safe handling, transportation, and storage of batteries and battery waste. Lote’s security services include security system design, CPTED (Crime Prevention Through Environmental Design), security risk assessment, data security, cybersecurity, and regulatory compliance.
Further information can be found on the Lote Consulting website.
4. NSW LITHIUM BATTERY RECYCLING REGULATORY GUIDELINE
ABRI members, NSW and Commonwealth Government representatives, and stakeholders met 4 May to discuss the work in progress version of the NSW Battery Recycling Regulatory Guideline.
The project is being led by Sydney University Associate Law Professor Penny Crossley. ABRI and Professor Crossley welcome feedback from all members on the structure, approach, content and technical information. This will assist the research team add, polish and refine information in the guide over May/June with a focus on the needs of industry.
There are still sections on planning, reuse and embedded batteries to be added and case law examples to be included. And yes, for those who like detail, you will no doubt pick up some errors. Please let us know what needs to be corrected.
At the workshop, there was also discussion on priorities for policy/regulatory work to be undertaken to support battery recycling industry investment. Initial observations are:
classifications and multiple definitions of batteries are complex and creating uncertainty
could batteries with no charge not be removed from dangerous goods classifications
what activities could reduce risks associated with handling used lithium batteries?
defining used batteries as waste is potentially adding administrative cost and limiting industry’s ability to support a battery circular economy – batteries are a good product for high levels of resource recovery and this should be supported in a safe and sustainable way
damaged battery regulatory framework needs more work to support safety but also not limit all other battery recovery activities
investing in the needed infrastructure today to support the substantial volume of batteries (EV and energy storage) coming down the pipeline is taking time and being delayed due to the long approvals processes
best practice safe storage at consolidation and large scale ‘waste’ collection and aggregation sites (e.g. scrap metal) is still a work in progress
battery reuse – limited information/guidance on standards and consumer protections and regulatory approvals is seeing some novel approaches emerging – defining batteries as waste is also creating challenges
ABRI looks forward to engaging with all members on the development of this guideline and understanding industry priorities.
5. BUNDABERG REGIONAL COUNCIL TENDER FOR RECOVERY OF NON-LEAD ACID BATTERIES (DUE 16 MAY)
ABRI affiliate member, Bundaberg Regional Council, has asked ABRI to let members know that a tender for the recovery of non-lead acid batteries is now open (closes 16 May). Further information is available here.
6. SUPPORTING SAMOA WITH EV BATTERY RECYCLING
The United Nations Development Program (UNDP) would be interested to talking to any ABRI members who might be able to support EV battery recycling in Samoa. This includes bringing the batteries back to Australia for processing. Further information and contact details can be found here.
ABRI is also discussing with the UNDP whether there is other training or assistance that can be provided.
7. AUSTRALASIAN INSTITUTE OF DANGEROUS GOODS CONSULTANTS (AIDGC) – WHO ARE THEY? HOW DOES THEIR WORK RELATE TO BATTERIES? INFORMATION SESSION 1PM, MONDAY 5 JUNE
Frank Mendham, the AIDGC President will provide an overview of the AIDGC with a specific focus on batteries. Please email if you’d like to receive an invite to the presentation.
AIDGC is an independent industry body with over 60 member consultants that:
Sets and administers standards of conduct and competency of members
Requires members to update and demonstrate specialised knowledge, expertise and experience in dangerous goods matters. Continued membership includes competency reassessment.
Contributes to the development and review of dangerous goods Regulations, codes of practice and industry standards.
Provides and requires mandatory ongoing training and development for members, including increasing knowledge of, and expertise in, the conduct of DG hazard assessment and related risk management.
8. VISIT THE UPDATED AUSTRALIAN BATTERY INDUSTRY ASSOCIATION (ABIA) WEBSITE – COLLECTIVELY ENSURING A TRUSTED TRANSPARENT AND SUSTAINABLE BATTERY INDUSTRY IN AUSTRALIA
ABIA has revamped its website to support consumers and industry with information on purchasing batteries, safety and product quality.
For those not familiar with the ABIA, it is the industry association specialising in aftermarket batteries for the automotive, marine, industry and recreational segments of the battery market. It represents companies in battery manufacturing, importing, distribution and/or retail operations across Australia primarily for lead acid and lithium batteries by:
Promoting the interests of the Australian Battery Industry
Advocating for and drive best practice
Strengthening safety for everyone in the battery value chain
Minimising environmental impacts throughout the battery life cycle
Providing a strong and unified voice on the views and interests of members involved in the Australian Battery Industry
9. REMINDER - CONSULTATION ON PROPOSED EV BATTERY STEWARDSHIP SCHEME – SUBMISSIONS DUE 15 MAY
The Battery Stewardship Council, Federal Chamber of Automotive Industries (FCAI) and Motor Trades Association of Australia (MTAA) is consulting on options for EV battery stewardship. The discussion paperasks a number of questions about challenges and current knowledge within the sector that could be used to inform an outcome.
Feedback is sought by 15 May. The proposed next steps are release of the First Options Paper in July 2023, in advance of workshops in Sydney and Melbourne in August. The resulting Firm Options paper will be released in the second half of 2023 followed by further workshops.
ABRI is currently preparing a response which highlights:
Giving precedence to the development of commercial solutions
The full range of policy options to achieve battery circular economy outcomes with the objective of maximising efficiency and minimising costs to consumers
Minimising administrative costs and red tape where safe and sustainable to do so
Consistency with policy developments and regulation overseas, such as producer responsibility and battery tracking rules, to maximise and leverage existing opportunities and removing the need for duplicative frameworks
Ensure urban, regional and remote areas can access battery recycling opportunities