• European Green Deal - https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal_en

• Circular Economy Action Plan - https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en

• EU Taxonomy - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852

• Directive 2006/66/EC - https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32006L0066

• Directive 2008/12/EC - https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32008L0012

• Directive 2008/103/EC - https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32008L0103

• Directive 2013/56/EU - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32013L0056

• Regulation (EU) 493/2012 - https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0493

• Commission guidelines - http://ec.europa.eu/environment/waste/batteries/pdf/Guidelines%20on%20RE.pdf

• Consolidated version Battery Directive 2006 - https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02006L0066-20131230&rid=1

Batteries are made of various components (cathode, abode, electrolyte, separating media, BMS (Battery Management System), external casing, etc.

Each of those sub-systems are made of various materials (LiCoNi oxides, plastics, graphite…).

A battery as such is deemed to be a product under REACH, CLP and Extended Producer Responsibility Legislation.

Here is a brief summary of the various obligations:

1. For recycled chemicals used again in the industry

a. Registration under REACH (although if some conditions are fulfilled, a recycler may enjoy an exemption to the registration step - Art 2.7.d of REACH).

b. The CLP regulation (with a SDS and an exposure scenario per use identified if so required).

c. SVHC management: there is a list of more than 200 substances of very high concern for which additional duties are imposed (notification, communication in the supply chain, etc.).

d. Restriction or authorisation regimes under REACH (for some very specific substances - there is no such substances included in batteries to our knowledge).

2. For products

a. Product safety regulations

SVHC management and SCIP database

• Waste framework directive (2008/98/EC) - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32008L0098

• Battery directive (Directive 2006/66/EC) - https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32006L0066

• WEEE directive (2012/19/EU) - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012L0019

• ELV directive (2000/53/EC) - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02000L0053-20200306

• Waste shipment regulation (Regulation (EU) 2015/2002) - http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32015R2002&from=EN

• European Waste List - https://ec.europa.eu/eurostat/documents/342366/351806/Guidance-on-EWCStat-categories-2010.pdf/0e7cd3fc-c05c-47a7-818f-1c2421e55604

Safety is the first concern of actors involved in the management of end-of-life batteries from collection, refurbishing for second life, transport, storing, sorting to recycling and recovery of secondary materials.

As soon as one of the above operations modifies the integrity of a battery (or one of its components like the cells), new risks can pop up and create an impact on human health or the environment. The safety legislation provides a minimum framework to handle those risks, although per definition zero risk does not exist.

Physical-chemical impacts

Examples of physical risks are explosion, fires, fast combustion, leaks of gases or acids, etc. These can cause severe damage to humans and the installations.

Depending of their chemistry, some batteries contain flammable electrolytes, or very reactive chemicals that can cause a chain reaction of combustion.

Human Health impacts

Exposure to harmful chemicals is the critical parameter here. Batteries contain chemicals that are regulated under the Occupational exposure legal framework. For example, exposure of workers to some compounds of Ni, Co.. when recycling batteries or when producing new battery grade materials from batteries.

Environmental impacts

The last category is made of environmental risks like emissions to the environment (air, water, soil, sediments) creating a pollution. Such environmental impacts can be contained when part of a well establish recycling process, but the situation can be completely different in case of incident, road accident, or any unforeseen circumstances.

Safety during transport

The risks during transport are subject to some legislations at UN level. Some of them have been translated in the EU legal, framework (like ADR for road transport, specific to Europe and some other countries, but replaced by other types of legislations in some part of the world), others remain international per definition (IMDG/IATA).

Some batteries are subject to transport regulations like:

• ADR (road transport)

• IMDG (sea transport)

• IATA (air transport)

• Other pieces of specific legislation: RID for rail transport, for inlands waterways, ADNR for navigation on the Rhine river, etc.

The risks during transport are different when newly manufactured batteries are considered or when transporting damaged, defective or end-of-life batteries. For these reasons, the prescriptions to ensure a safe transportation are different in function of the position of a battery in the whole battery chain. The matter is rather complex. Some professional battery associations such as EBRA have joined forces to sponsor two e-book about the safe transportation of batteries;

• For Li-Ion batteries

• For all other type of batteries.

The e-books are freely available on the following website: https://www.batteriestransport.org/section/299/digital-library.

Because the UN framework is revised / updated every 2 years, the e-book will be also be updated from time to time. For this reason, the e-books are only available for online reading. A decision tree is available allowing you to find your way in this rather complicated matter.

• ADR - https://unece.org/transportdangerous-goods/adr-2021-files

• IMDG - https://www.imo.org/en/OurWork/Safety/Pages/DangerousGoods-default.aspx
https://www.imo.org/en/publications/Pages/IMDG%20Code.aspx

• IATA - https://www.iata.org/en/publications/dgr/

• BatteriesTransport website - https://www.batteriestransport.org/