The current 2006 Batteries Directive identifies three categories of batteries. A fourth one – for batteries in Electric Vehicles (EVs) – is already included in the December 2020 legislative proposal currently being discussed by the European co-legislators.
In support to this ongoing legislative process, a new JRC report explores modernisation of the collection rules (e.g. definition of the additional fifth category, alternative collection targets for Member States) to ensure the efficient, safe and fair collection of waste batteries from LMTs.
This is especially relevant given the growing discrepancy between the large number of innovative products placed on the market and the waste volume becoming available much later, due to longer lifespans of e-bike batteries (typically 9 years), compared to the assumed 3 years in the current collection target definition.
The main conclusion of the study underlines the need for an alternative target to compensate for this discrepancy leading to mismatches between the collection target and the volume available as waste over time.
Why a new category for LMT batteries would contribute to better collection and recycling
At this point, due to the technical development and cost reduction of increasingly versatile lithium batteries, it is uncertain how many new LMT applications will appear on the market in the coming years.
With a potentially significant volume of waste expected in the future, this might affect the collection and recycling stages for these batteries. Moreover, with higher energy density and larger battery packs compared to portable batteries, safety in handling and collection requires specific attention.
With the fifth LMT category of batteries as defined by the JRC, a dedicated return channel including sport-shops, bicycle and scooters dealers would have environmental benefits.
Moreover, the study suggests that other non-collection requirements, such as sustainability, information and remanufacturing plus safety during collection and handling related requirements could be aligned to the specific characteristics of LMT batteries.
The most "future-proof"approach: switch targets on an "Available for collection" basis
This JRC report explores the application of the "Available for Collection" (AfC) method – an alternative to current methodology which establishes collection rate targets based on the quantities that become available as waste.
The main recommendation is therefore for a modernisation of the target basis, converting the placed-on-market (POM)-based target in the legislative proposal – based on sales in the 3 preceding years – to an AfC-based target, in anticipation of highly uncertain future waste volumes for both LMT and portable batteries.
The more dynamic the future market for LMT and portable batteries, the more reason there will be to consider AfC-based targets, which better reflect actual waste battery volumes.
This JRC report considers the development of an AfC-based common methodology to be feasible. It would more accurately reflect the waste volumes in the EU and per Member State, based on the specific development of their national markets.
Adopting the alternative approach would make it possible to have collection targets already by 2025 instead of 2030 and would be more "steadily challenging" compared to the original one based on POM.
This work contributes to the preparation of the implementation of the draft Battery regulation proposed by the European Commission in December 2020, especially concerning collection provisions for waste portable batteries.
The draft regulation explicitly states that “the JRC will play a key role in supporting the Commission with some of the technical work required”, which refers to a range of foreseen measures steering towards more sustainable batteries for the EU in the future.
The Commission proposal for a Regulation on Batteries (COM(2020)798 final) includes targets for the collection rate of waste portable batteries based on the Batteries Directive (EC/2006/66), which uses the POM approach. For the moment, these targets exclude batteries that power LMT products until 2030.
Instead, the proposal contains a review clause that requires the setting of a separate collection target for waste batteries that power LMTs in light of the evolution of the market.
The Commission took on the commitment to explore the possibility of establishing collection rate targets based on the quantities available for collection, including as regards LMT batteries, in the ongoing legislative process. The recently published JRC report presents the results of this exploratory work.
JRC study: Battery storage