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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