29 March 2023

1. BATTERY RECYCLING INDUSTRY PRIORITIES - REDUCING ADMINISTRATIVE BARRIERS AND INSURANCE COSTS

The initial feedback from ABRI members is clear – reduce administrative burdens and insurance costs.

Preliminary results from ABRI’s member survey reveal actions of most benefit to supporting battery recycling industry growth are:

  1. Streamlined and clarified regulatory environment and processes

  2. Funding for: safety; proof of concept and research & development; and collection networks

  3. Best practice guidance on storage and transport

While the top three barriers are:

  1. Insurance costs – insurance is taking more time to search, usually greater than a week. Costs have generally risen between 50 to 100% in the last 12 months and in some instances more.

  2. Regulatory – administrative costs, conflicting information and lack of clarity

  3. Transport costs for packaging and sending used batteries to recyclers

These results are based on feedback from 13 members who have responded to ABRI’s survey on priorities and challenges for the battery recycling industry. They represent recycling businesses across the main chemistries – lead acid, lithium, alkaline and zinc carbon. The results will be used to prioritise ABRI’s work program and inform advocacy priorities. The survey is still open to members who would like to contribute to the discussion.

2. OVER 1,500 VISITS TO ABRI’S WEBSITE TO FIND COMMERCIAL BATTERY RECYCLING SERVICES

The ABRI website function to search for commercial battery recycling services is by far the most visited section of the website. This clearly indicates there is great interest from businesses to improve their battery recycling practices.

In the March Quarter, there were over 1,500 visits to search for commercial battery recycling services. This compares with over 850 visits on how to find a drop off point for household and small battery collections – the next most visited section of the website.

ABRI, with input from the ABRI Member Communications Working Group, is refreshing the ABRI website content to better promote member services and ABRI’s focus on the B2B segment of the market.

Updating the ABRI website to reflect ABRI’s name change to Association for the Battery Recycling Industry is also a key part of this work program.

Please check your member profile on the ABRI website to make sure that visitors searching for your services can clearly see what you provide.

ABRI is also developing a service provider section on the website to showcase members who provide consulting, technical, dangerous goods and other services to the battery recycling sector.

3. NSW LITHIUM BATTERY RECYCLING REGULATORY FRAMEWORK - WORKSHOP 2

ABRI and Associate Professor Penny Crossley (University of Sydney Law School) will hold the second workshop on the development of the NSW Lithium Battery Recycling Regulatory Guide.

The workshop will be run in two parts:

  1. Presentation and feedback on the draft guide covering topics such as: Battery and product classifications; Planning approvals and conditions; Environmental approvals and conditions; Transport and dangerous goods approvals and conditions; WHS requirements; Waste definitions and implications for battery landfill bans and resource recovery; and export permits.

  2. Working group discussions on priorities for further work.

Workshop Details and Draft Agenda

1pm to 4.30pm, Thursday 4 May
Law Foyer in the New Law Building, University of Sydney
RSVP: secretariat@batteryrecycling.org.au or call Katharine Hole, ABRI CEO on 0488 216 750.

4. ABRI THE BATTERY RECYCLING INDUSTRY’S VOICE TO THE NATIONAL BATTERY STRATEGY

ABRI’s submission to the National Battery Strategy advocated for support to realise Australia’s potential as a world leader in battery recycling and supplier of downstream feedstock for battery manufacturing. ABRI recommended that the strategy should prioritise:

  • Batteries are recycled in Australia, where there is available capacity, underpinned by locally developed technology and innovative processes. Consideration should also be given to processing black mass in Australia to extract the critical minerals.

  • Minimisation of regulatory costs and red tape where safe and sustainable to do so. A recent ABRI member survey shows that inefficient and conflicting regulatory processes are a major challenge and barrier for business.

  • Consistency with policy developments and regulation overseas, such as producer responsibility and battery material traceability rules (e.g. European battery passport), to maximise and leverage existing opportunities. Energy storage and EV companies are already tracking batteries and Australian recyclers are part of the barcode tacking process to confirm batteries have been recycled.

  • Australian recycled materials can be used to meet the requirements for minimum recycled content in new batteries applied in other countries.

  • Ensures urban, regional and remote areas can equally access battery recycling opportunities.

5. DEVELOPING A PATHWAY THROUGH THE INCREASING WEB OF SCHEMES TO MANAGE BATTERY END OF LIFE

ABRI is developing a battery recycling industry policy position on the optimal approach for managing an increasingly complex web of commercial, voluntary and government stewardship schemes which impact end of life batteries. To support this work, ABRI CEO, Katharine Hole, is asking interested members to discuss their views on the mounting range of government programs, stewardship and OEM commercial requirements for recycling end of life batteries.

Overseas and in Australia, there is growing interest in how to ensure batteries are recycled and the valuable resources recovered. Models for end of life battery management include formal stewardship schemes and mandating producer responsibility with producers to manage end of life batteries themselves. This is in addition to EV company public commitments to reuse, repurpose and recycle batteries. Regardless of the model implemented, tracking of large batteries is emerging to meet recycled and material provenance rules.

OEMs are already starting to initiate and manage battery tracking, for example barcoding batteries, to deliver public sustainability and circular economy commitments. ABRI is aware that EV and BESS companies are directly seeking out ABRI members to discuss commercial opportunities. In some instances, commercial agreements are already in place. Experience shows that OEMs are also actively developing and managing their own product stewardship for large batteries.

In this context, principles that could be considered to inform ABRI’s position on stewardship approaches in Australia are:

  • All batteries are recycled in Australia underpinned by a world leading battery recycling sector and local technology

  • Precedence for the development of commercial solutions

  • Safety at all stages of the supply chain

  • Minimising costs and red tape where safe and sustainable to do so, as discussed above minimising administrative costs is critical

  • Consistency with policy developments, business practices and regulation overseas, such as producer responsibility and battery tracking rules, to maximise and leverage existing opportunities

  • Ensure urban, regional and remote areas can access battery recycling opportunities

  • Where a battery stewardship scheme is the only solution, then it should apply strong corporate governance principles including: independent oversight and dispute resolution; appropriately skilled and resourced compliance and enforcement teams; and strong focus on minimising administrative burdens.

At a minimum, policy proposals should be cost effective and efficient solutions so that battery recycling can support a low-cost, clean energy transition.  ABRI is looking to understand what the evolving situation means for the entire used battery supply chain from battery collection through to recycling. This includes if differences in chemistries (e.g. lead vs lithium), applications (e.g. small vs large) and commercial arrangements will require bespoke solutions.

Please discuss your priorities and/or provide written comments to the ABRI CEO, Katharine Hole, by 28 April 2022 via email to secretariat@batteryrecycling.org.au or phone on 0488 216 750. The ABRI Secretariat will collate themes from the submissions to potentially inform a workshop with ABRI members on industry policy positions.

Background on Battery End of Life Stewardship and Management Schemes

In addition to some states and territories, banning batteries and/or e-waste in landfill, Australia already has five stewardship schemes involving end of life batteries that are operating or underdevelopment:

  • B-cycle for small, loose batteries, which has seen collection rates double

  • NTCRS, which captures batteries embedded in eligible e-waste products

  • Mobile Muster, which captures batteries embedded in eligible products

  • FCAI/BSC proposal to manage batteries at end of vehicle life

  • Draft Queensland E-products action plan which is looking to capture energy storage batteries

Commercial arrangements may also require battery recyclers to:

  • Meet international standards such as R2 for e-waste stewardship or a battery equivalent

  • Track battery material in preparation for compliance with minimum recycled content in batteries in other jurisdictions as well as to demonstrate delivery of OEM public circular economy commitments at point of sale

There is a lack of clarity on how all these programs will interact domestically and with international arrangements.

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3 April 2023