Has the European Commission made any progress on the much needed definitions of second life, reuse and waste in relation to car batteries?
“Based on conversations with the European Commission, I suspect that there may well be an amendment to the Battery Directive by 2020. The amended laws and regulations will then enter effect in the member states by 2022. According to a working document from the European Commission, there will be many changes. For instance, there will be an improvement to the collection of materials to be recycled and there is a desire to step up recycling. It will also refer to the harmonised introduction among member states and include specific definitions in the legislation and regulations. I strongly suspect that it will include a definition of reuse and second life. It is also evident that there will be clear criteria concerning lithium batteries.”
Green Light looked at the potential amendments to the ELV Directive a while ago after a meeting with Artemis Hatzi-Hull, who is responsible for the ELV Directive in the European Union.
One criticism of the current Battery Directive is that the legislation lags behind developments in technology. Is that also going to be addressed?
“The European Commission acknowledges that the legislation is lagging behind rapidly evolving developments in technology. They say that they would like to revise the Battery Directive in such a way that it will automatically incorporate new technologies coming onto the market. In accordance with the circular economy, I think that it may be valuable to think slightly more broadly. By aligning the legislation more closely to the circular economy, it will be possible to use products for longer. After raw materials have been recycled, it will be possible to reuse them without having to extract new raw materials.”
What will be the effect of the amendment to the Battery Directive, including clear definitions of the most important terms, on industry?
“If you want investors to focus on new technologies, this needs to be supported, not constrained, by the legislation. The current legislation, including the definitions, is interpreted in different ways in the various member states. Potential investors in the reuse and repurposing of batteries do not know what they are allowed to do and what they are not. This is more related to interpretation rather than the exact legislation. I think that’s a shame. In my view, that needs to be addressed so that a new business model can emerge from this.”
“Furthermore, people are increasingly looking at the opportunities of remanufacturing. Remain (remanufactured) engines and transmissions, which are already well known, will also be followed by remanufactured batteries. These remanufactured batteries will enable specialists to add a new product line to their range. This will mainly be in direct partnership with the car manufacturers. It is an interest development to follow.”
An improved Battery Directive is the basis for the reuse or repurposing of old EV batteries. But you think beyond that. That is why you are also arguing for a good diagnosis.
“What we propose is that if a battery no longer works in a vehicle, it will then undergo diagnosis by a professional. This professional will decide whether the battery, or any of its components, can be further used in a product, or if it will become waste. That diagnosis can also be undertaken at a dismantling company if the company has the required knowledge and expertise in hybrid and electric vehicles. In fact, I’m making the argument for a revalued specialised company that is a kind of enhanced dismantling firm.
Green Light previously visited one of these so-called battery professionals: “The remanufactured battery is the future”
Willy Tomboy was associated for many years with RECHARGE, the European industry association for advanced rechargeable batteries. He was previously the Director of Environmental Affairs & Corporate Citizenship at Toyota Europe. He currently works as an independent consultant in the fields of mobility, the environment and sustainability.