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EGARA had her Fall meeting 2017 in Brussels again. Besides the usual topics of the association, like finances and action plan and so, batteries took most of the time we spent together. Main reason for this is the Battery Directive consultation that ended last november 28th.

EGARA wanted to respond to this consultancy for more than one reason. Most important is we will be in the system as a stakeholder and be invited to consultation meetings or workings groups. The other important reason is we want have our interests noted at the EC.

What is going on about batteries and their Directive? In short: technological developments have gone way faster than legislation could keep up with. So in regards with lithium-Ion (li-ion)batteries from hybrids/electrical vehicles (H/EV), the Directive has become obsolete. Traction batteries for H/EV are li-ion and even starter batteries are in some models no longer lead-acid, but Li-ion.

The battery Directive has some goals like banning or reducing hazardous materials in batteries, producer responsibility and reporting about recycling. Also some directions for facilities are mentioned in the annexes, like the better known ELV Directive does. But for Li-ion batteries, nothing is taken care of.

We have mentioned the flamability of the electrolyte. We can take care of these batteries, but we do not need expensive fancy applications if simple ones can fulfil the job.For example: the current Directive dictates containers, while for Li-ion batteries this is counter productive in case of fire.

Producer responsibility (EPR) is another thing. For lead-acid batteries, the last owner can have them collected without costs for the take back. For industrial and traction batteries, it’s unclear. Problem is, lead acid batteries always have a positive value. Even if the EC ants lead to be fased out, it’s in fact the lead that makes them a perfect example of a circular economy product. Li-ion is a different case. Broken cells only cost money to have them recycled. If they need to be paid for to have them recycled (or even accepted), it’s not really an incentive to have them end in the right places.

Another thing about EPR is going on. As long as batteries can be reused, they can be sold. No problem if ownership isn’t preventing anyone from doing so. If batteries get under 80% capacity, they are no longer fit to function as traction batteries, but they can be recycled for energy storage for companies or housekeepings. The functioning cells are used for new devices. It’s no longer a car battery, then. So there’s still value in the old batteries. The recycler however, becomes a producer from this moment and EPR is now the new producer’s responsibility. The high recycling costs come when these devices reach the end of life fase. They are just postponed with the second life as energy storage device. On the other hand, the older EV’s are getting, the more cells from a traction battery need to be recycled under the producers EPR. Here’s our risk, even if it’s in the near future.

The message we want to give in the consultation is clear:

  • –  We are the facilities to take care of H/EV’s;
  • –  We can distinguish functioning batteries from batteries that need to be recycled;EGARA-Secretariat
    c/o STIBA Pompmolenlaan 10, NL3447 GK Woerden The Netherlands Tel: +31 88-5011090 e-mail:
  • –  We can dismantle them from the vehicle and store them for collection and recycling;
  • –  Any directions need to be dynamic;
  • –  Producers should not be ably to simply avoid EPR or tranship costs to others.EGARA filled in the consultation and so did most EGARA members. If anything happens, we keep you informed. Anyone that has experience with batteries and EV’s, is welcome to share it with us. Vehicle technology is changing faster and faster. We need to keep up with it.