Submissions

• Wired for Change – regulation for small electrical products PV and energy storage battery stewardship

  To inform the least cost and most efficient and effective model for producer responsibility, ABRI considers the preferred course of action is the following: 

  • Establishing an information sharing and data framework, such as the European battery passport.  
  • State based strategic planning for collection and aggregation sites to minimise transport costs and support safe collection.  

  • Streamlined planning and environmental approvals for used battery collection and aggregation sites.  
  • Consistent safe storage, handling and transport guidance for collection, aggregation and recycling sites across Australia. 
  • Development of robust standards and a consumer protection framework to support safe battery repurposing.  
  • Mapping of the logistics chain to understand what challenges need to be addressed and opportunities are arising and therefore assess producer responsibility options. 

  Wired for Change consultation paper

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• Economic evaluation of B-cycle collection and sorting processes

  The Battery Stewardship Council is reviewing B-cycle economics and requested information from ABRI.

  ABRI’s response highlighted:

  • Timely to review the economics of the scheme and look to continuous improvement as the scheme matures from its start-up phase.
  • Congratulations to BSC on the successful start to the scheme and appreciates the substantial work put in by the BSC team in the start up phase. 
  • Observations about about the economics of collection and sorting processes: 
    • Administrative and audit process
    • Lack of flexibility to support a variety of collection models
    • Transport costs are rising 
    • The rebates only partially cover operating costs and therefore do not contribute towards capital investment
    • The definition of metro is broad and does not reflect the operating practices and realities of the industry

   

   

   

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• ADG Comprehensive Review – Fire extinguisers and safety equipment

  The National Transport Commission is undertaking a comprehensive review of the ADG (Australian Dangerous Goods) Code which will ultimately result in ADG8.

  ABRI commented on proposals around the number of fire extinguisers and respiratory equipment to support safe and sustainable transport.

   

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• ABRI Priorities for EV Battery Stewardship – BSC/FCAI/MTAA consultation

  ABRI will continue its work with all stakeholders to support 100% recycling of EV batteries in Australia and the growth of the local battery recycling industry.

  ABRI has been advocating for the following industry priorities: 

  • Information sharing and data on battery chemistry and disassembly to support safe and sustainable recycling, reuse and repurposing. 
  • State based strategic planning for collection and aggregation sites to minimise transport costs and support safe collection. 

  • Streamlined planning and environmental approvals for collection and aggregation sites. 
  • Funding for proof of concept testing to ensure recyclers are ready at scale and to manage financial uncertainty at the early stages of industry development as volumes are not yet commercial. 
  • Consistent safe storage, handling and transport guidance for collection, aggregation and recycling sites across Australia 
  • Development of robust standards and a consumer protection framework to support safe battery repurposing. 
  • Funding for research to develop solutions to partial processing of used EV batteries on a smaller scale to reduce costs in transporting batteries from remote and regional areas. 
  • Review of hazardous waste import permit fees to support the building of domestic capacity as a South Pacific hub. 

   

  BSC-FCAI-MTAA EV Stewardship Discussion Paper

   

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• Queensland Draft E-Product Action Plan

  A joint submission with Associate Professor Penelope Crossley from the University of Sydney Law School. The submission draws on the learnings from a research project ‘Regulating for resources: Regulating the battery lifecycle so that they can safely become a feedstock for new products’ due for completion in June 2023. Associate Professor Crossley and ABRI are jointly collaborating on this project.

  The submission focuses on: reuse and repair; consumer empowerment; procurement; infrastruture and transport; and policy and regulatory reforms.

  Draft Queensland E-Product Action Plan Consultation

   

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• National Battery Strategy

  ABRI (the Association for the Battery Recycling Industry) strongly supports the development of a National Battery Strategy to provide a sovereign capability and maximise investment opportunities across the battery value chain. 

  ABRI’s submission sets out a framework for developing and the priority, no regrets action for progressing battery recycling.

  National Battery Strategy Consultation Paper

   

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