NOVEMBER 2023

ELECTRIC VEHICLE
BATTERY END-OF-LIFE
MANAGEMENT
Information Sharing Gaps andthe Current State of Practice
BUSINESS WHITE PAPER
MOBI EOL0001/WP/2023
VERSION 1.0

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END OF TERMS AND CONDITIONSMOBI EOL0001/WP/2023 Version 1.0

INTRODUCTION

MOBI EOL0001/WP/2023 Version 1.0

Lead Authors:

Rajat Rajbhandari, PhD, MOBI
Betul Kahya, MOBI
Matt Shi, MOBI

The issuance of this standard as a formal MOBI standard was conducted by MOBI and its members.

Co-Chairs:

Pramita Mitra, Ford

Reviewers:

Yasuhiko Ogushi, Kaula Labs

Contributors:

Praveen Abbaraju, Hitachi America Ltd

Sanshiro Fukao, ITOCHU

Steve Amancha, State Farm

Matteo Gandolfi, Henshin GroupThe procedures used to develop this document and those intended for its further maintenance are described inMark Anders, Ford

Fabrizio Garetto, Stellantis

the working group charter. In particular, the different approval criteria needed for the different types of MOBI

Hiromasa Aoki, Trade Log

Kamil Gaweda, Arxum

Alessandro Arciero, Henshin Group

Avinash Ghorpade, DENSO

Mitsuharu Arinori, Trade Log

Alan Gordon, Ford

Anna Baranskaya, NissanMichael Gorny, Stellantis

Patrick Bartsch, AWS

Kumara Guru, Blockedge

Massimo Belluz, Henshin GroupIvan Gutierrez, State Farm

Roger Berg, DENSO

Shigemitsu Hara, Orico

Manjiri Birajdar, Arxum

Kinoshita Hiroshi, Mazda

Mike Brown, Nissan

Felix Huang, DENSO

Lucie Chabert, Stellantis

Yawen Huang, DENSO

Raullen Chai, IoTeX

Chris Hwee, Honda

Alex Choo, ASJade Tech

Momo Ichihara, Trade Log

Nicola Cianci, Stellantis

Tooru Inoue, Orico

Kerry Cote, State Farm

Alvin Ishiguro, Trade Log

Claudia Damari, Henshin Group

Hitoshi Iwamoto, Honda

Pierre Delaunay, Stellantis

Nick James, AWS

Steven Douglas, DENSO

Sajit Janardhanan, AWS

Steve Dunstan, State Farm

Mikael Johansson, Toyota

Olivier Emsalem, Stellantis

Industries Corporation

Miho Etchu, Trade Log

Masaru Kakuchi, Orico

Xinxin Fan, IoTeX

Kazuya Kamata, Trade Log

Josh Fodale, Ford

Motohisa Kamijo, Nissan

Aaron Fong, Honda

Ami Kamikihara, Trade Log

Jean-Marc Fournier, Stellantis

Okamoto Katsuji, Kaula Lab

Masahiro Fujita, Trade Log

Naoyuki Kawaguchi, Trade Log

MOBI is a nonprofit alliance of many of the world’s largest vehicle manufacturers, startups, governments/
transit agencies, NGOs, financial institutions, e-mobility providers, consultancies, suppliers, logistics providers,and blockchain protocols working to create standards and build the Web3 digital infrastructure for connectedecosystems and IoT commerce. The work of preparing standards is carried out through MOBI working groups.

Fabio Severino, Traent

Each member of the consortium interested in a subject for which a working group has been established has
the right to be represented and participate in that working group. Mobility providers, technology companies,
governments, and NGOs, in liaison with MOBI, take part in this work.

documents should be noted. Approvals of MOBI Steering Committee and Board of Directors are obtained upon
the final document release. Attention is drawn to the possibility that some of the elements of this document
may be the subject of intellectual property rights. In accordance with MOBI IPLR policy, a 60 day review
period is provided to the MOBI community to disclose any and all IP matters pertaining to this standard. MOBI
shall not be held responsible for identifying any or all such rights. Details of any IP rights identified during thedevelopment of the document will be in the Introduction upon public release of this standard.
Any trade name used in this document is information given for the convenience of users and does not constitutean endorsement. The working group responsible for this document is the Supply Chain (SC) Working Group.
Sincere thanks and appreciation are extended to those who contributed their unique insights to this report.

MOBI EOL0001/WP/2023 Version 1.0

Contributors
Continued:

MOBI EOL0001/WP/2023 Version 1.0

Hiromi Kawanishi, Mazda

Rodolfo Occari, Toyota Industries

Raj Srinivasaraghavan, Blockedge

Huub van der Wouden, Toyota

Yoji Kawanishi, ITOCHU

Corporation

Sudha Sriram, Ford

Industries Corporation

Ogawa Kazuya, Toyota Industries

Yasuhiko Ogushi, Kaula Lab

Suresh Sundaraj, Ford

Takuya Watanabe, Anritsu

Corporation

Hidenori Ohashi, Aucnet

Yoshinori Suzue, Nissan

Takashi Watanabe, Anritsu

Ohashi Kenji, Toyota Industries

Shuichi Ohki, Kaula Lab

Hirotaro Suzuki, AUCNET

Tony Welcome, State Farm

Corporation

Harunobu Ohmae, ITOCHU

Tetsuya Takahashi, Hioki

Ross Wheeler, State Farm

Toru Kimura, Honda

Tomonori Okada, Toyota Industries

Yuhei Takai, ITOCHU

Spencer White, Ford

Kim Kloeppel, State Farm

Corporation

Kimihito Tanaka, Toyota Industries

Phil Windley, AWS

Christian Koebel, Honda

Mitsuyuki Okano, Orico

Corporation

Hu Xu, Toyota Industries

Yasuhiro Komine, Honda

Adewale Omoniyi, AWS

Leonardo Tapanelli, Stellantis

Corporation

Karthik Krishnamurthy, AWS

Shinji Omuro, Toyota Industries

Jan ten Hove, Toyota Industries

Xin Xu, DENSO

Karthik Krishnan, AWS

Corporation

Corporation

Katsutoshi Yamazaki, Honda

Yasuyuki Kubota, Mazda

Tatsuro Otsu, Toyota Industries

Vitthal Thamke, Vitesco

Hideo Yoshida, Nissan

Sandeep Kulkarni, AWS

Corporation

Nakaya Tomofumi, Mazda

Yasuhiko Yuasa, Honda

Subrata Kundu, Hitachi America Ltd

Larry Pang, IoTeXLong Tran, AWS

Kitaoka Yusuke, Toyota Industries

Cedric Labry, Vitesco

Drew Paroz, Honda

Nonoyama Tsuyoshi, Toyota Industries

Corporation

Frederic Legrand, Stellantis

Sunil Paul, Spring Free EV

Corporation

Xiaoliang Zhu, Hitachi America Ltd

Phebe Lu, ASJade TechFrancesco Petrignani, Traent

Takayuki Udagawa, OricoThomas Ziebro, Vitesco

Vijay Madhavan, Blockedge

Damien Pierre, Stellantis

Ishii Makoto, Mazda

Christian Poulain, Stellantis

Will Maney, USAA

Lorenzo Prestia, Stellantis

Domenico Mangiacarpa, Henshin Group

Jonas Rahm, Toyota Industries

Hisashi Matsumoto, Anritsu

Corporation

Eiji Matsumura, Anritsu

Moin Rahman, State Farm

Diego Mazzieri, Stellantis

Mathias Reinartz, Stellantis

Brad Miller, National Automotive Dealers

Sandeep Saini, Vitesco

Association

Futoki Saito, ITOCHU

Takuya Mimori, Vitesco

Yoshihide Sakai, ITOCHU

Lauren Mitchell, State FarmDavide Salerno, Henshin Group

Pramita Mitra, Ford

Shoki Sato, ITOCHU

Stefano Monti, Stellantis

Otto Schell, Stellantis

Emmanuel Monzies, Stellantis

Takashi Sendo, Trade Log

Tsune Murai, Orico

Paras Sethi, ParkMyFleet

Hiroaki Murase, ITOCHU

Fabio Severino, Traent

Ash Naik, AAIS

Jigneshkumar Shah, DENSO

Hitoshi Nakajima, Orico

Vyacheslav Sharipov, AUCNET

Taro Nakata, Kaula Lab

Kenji Shibata, Toyota Industries

Yasuhiro Nakayama, AUCNET

Corporation

Matsuo Naoya, Trade Log

Mark Shih, ASJade Tech

Alberto Nasi, Stellantis

Kikuchi Shinichi, Mazda

Andrea Neri, Stellantis

Takahara Shinji, Mazda

Keisuke Nisugi, Toyota Industries

Erik Skyten, State Farm

Corporation

Sunil Srinivasa, Vitesco

MOBI Team:

Tram Vo, CEO + Founder
Chris Ballinger, Advisor + Founder
Rajat Rajbhandari, Head of Standards and Certification
Andreas Freund, CTO
Parth Bhatt, Technical Product Manager		
Griffin Haskins, Mobility Finance Lead
Matt Shi, Supply Chain Lead
Betul Kahya, Mobility Lead
Grace Pulliam, Communications Manager
Kierra Maggs, Digital Media Associate

Contact:

connect@dlt.mobi

MOBI EOL0001/WP/2023 Version 1.0

MOBI EOL0001/WP/2023 Version 1.0

TABLE OF CONTENTS
1. Executive Summary
2. List of Acronyms

01
1
2

EXECUTIVE SUMMARY

This document focuses on information

Various proposed regulations in the European Union (EU), United

sharing between supply chain entities

States (US), and other global regions will require information sharing

during the EV battery’s end-of-life (EOL),
including an evaluation of the parties
responsible for EOL management.

3. Objectives of this Document3

4. Information Sharing in EOL Management

4

5. EV Battery End-of-Life

5

6. Parties Responsible for Information Management

8

7. Collection, Storage, and Transport

12

8. Reuse and Repurposing of Used Batteries

1421

10. Proposed Regulations

25

11. Closing the Information Gaps

30

12. References

32

regulators, and end-users at an unprecedented level throughout the
lifecycle of batteries, such that changes to battery data can be tracked.
This document focuses on information sharing between supply
chain entities during the EV battery’s end-of-life (EOL), including anevaluation of the parties responsible for EOL management and the kindsof information they produce and share with their trading partners. This
document also identifies information gaps that could hinder compliancewith proposed regulations.

This document proposes various strategies

Finally, this document proposes various strategies to bridge thoseto bridge information gaps, including theinformation gaps, including the use of battery passports to share battery

use of battery passports to share battery

9. Recycling of Waste Batteries

about electric vehicle (EV) batteries between supply chain stakeholders,

EOL data.

EOL data. The authors of this document believe that MOBI’s Guideline on
Building a Decentralized Battery Passport System (June 2023) will play
an essential role in facilitating battery data sharing in compliance withproposed regulations and offers a necessary foundation for stakeholders
to meet their objectives of circularity and sustainability across the EV
battery lifecycle.

Courtesy of Inside Climate News© 2023 MOBI. All rights reserved.

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02

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LIST OF ACRONYMS
BMS

		 -

Battery Management System

03

OBJECTIVES OF THIS DOCUMENT

Efficient, end-to-end information sharing

Efficient, end-to-end information sharing and traceability throughout the EV

and traceability throughout the EV battery

battery lifecycle demonstrates transparency and compliance with various

lifecycle demonstrates transparency and

CalEPA			 -California Environmental Protection Agency

compliance with various battery regulations,battery regulations, enabling an audit trail for trading partners, end-users, andenabling an audit trail for trading partners,

regulators. However, the complexity of the EV battery supply chain has resulted

end-users, and regulators.

in information sharing gaps that pose obstacles to industry-wide compliance

EOL

		End-of-Lifewith regulations pertaining to battery recordkeeping and the traceability of

EU

		 -

The objectives of this document are twofold:materials.

European Union

EV			Electric
Vehicle•identify the information sharing gaps in EV battery EOL management, and•provide strategies to bridge those information gaps such that the supply
chain members can provide necessary battery information to the general

LiB			Lithium-Ion
Battery

public, regulators, end-users, and other concerned entities such as recyclers
and reusers.

OEM			 SOC		 -

Original Equipment Manufacturer
State of Charge

In order to identify such gaps, the SC

In order to identify such gaps, the SC Working Group (WG) mapped the current

Working Group mapped the current state

state of practice concerning the recycling, repurposing, and reuse of lithium-of practice concerning the recycling,
repurposing, and reuse of lithiu LiBs
installed on EVs.

SOH			 -

State of Healthion batteries (LiB) installed on EVs. As an example, the WG reviewed how theidentity of a battery pack is maintained throughout its lifecycle and examinedthe current state of practice with regard to battery serial number management
and unique battery identities. The WG also reviewed current and proposed
regulations pertaining to EV battery information sharing. The WG’s findings andUS			UnitedStates
USD			

United Stated Dollar

recommendations are enclosed hereafter.
Discussions in this document are limited to to LiBs installed in light, medium, andheavy-duty EVs, as LiBs are the most dominant type of battery chemistry in thecurrent market.

2© 2023 MOBI. All rights reserved.

© 2023 MOBI. All rights reserved.

3

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04

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INFORMATION SHARING IN EOLMANAGEMENT

In order for regulators to verify claims,

The European Union Battery Regulation and the proposed US Treasury’s Section

they must be able to “trace” the battery

30D Guidance require EV manufacturers and other supply chain members to

information and the associated data in theshare battery-related information with their trading partners, end users, andprovided claims.

regulators. Both measures require battery supply chain members to not only
provide battery information but also prove that the information is accurate and05

EV BATTERY END-OF-LIFE
5.1 Battery End-of-Life Definition

A product reaches its EOL when it no longer

A product reaches its End-of-life (EOL) when it no longer works as originally

works as originally intended, when theintended, when the battery is retired due to damage, and/or no longer operates

battery is retired due to damage, and/or nolonger operates at a sufficient capacity.

timely. In order for regulators to verify such claims, they must be able to “trace”

safety concerns.

This document analyzes information sharing gaps in the current state of practicetraceability throughout battery recycling, repurposing, and reuse in compliancewith current and proposed regulations. “Information sharing” in this document

A standard concept to specify a battery at

to measure a battery’s performance and determine whether it has reacheddefined for batteries.

the end of its intended first use. Battery SOH represents the total maximum
capacity at any time over the initial life capacity (rated capacity) of the battery.
SOC, on the other hand, is the remaining capacity over total capacity (or ratedof batteries during the process of EOL management.
In particular, this document analyzes the following with regard to recycling,pertains to EV battery supply chain

repurposing, and reuse:members exchanging data about the stateof batteries during the process of EOL
management.

•

capacity). SOH degrades over time; an EV battery is generally considered to beat the end of its first useful life when the SOH drops to 70% - 80%. However,a standard concept to specify a battery at EOL has not been unanimously or
clearly defined for batteries as they are complex electrochemical systems withnonlinear degradation behaviors.1 Battery EOL depends on design parameters

Identification of responsible supply chain members per the current

and the nature of the application, hence determining EOL can be complex.

state of practice and how regulations define the responsible parties
that would be held accountable for the timeliness and correctness ofWhen a battery reaches the end of its intended use, the responsible party

battery information.
•

removes the battery from the EV and, following an assessment, determines

Methods of maintaining a battery’s identity throughout its lifecycle

whether it will go to recycling or to a second-life application through reuse orin compliance with EU regulations (requiring the creation of a new

repurposing.

identity when a battery is repurposed and deprecation of identity oncethe battery is recycled).
•

5.2 The Need for EV Battery End-of-Life
Management

Access management for confidential battery information, such that
supply chain members can exercise control over which of their trading•

Battery State of Health (SOH) and State of Charge (SOC) are commonly used

EOL has not been unanimously or clearly

pertains to EV battery supply chain members exchanging data about the state“Information sharing” in this documentof the first life of an EV battery; that is, when the battery becomes unusable asoriginally intended due to performance degradation, physical damage, or otherthe battery information and the associated data in the provided claims.

and proposes methods to close those gaps in order to maintain information

at a sufficient capacity. It is important to note that the EOL here refers to the end

partners can access specific data.

Battery lifecycle traceability is now more

EV sales are rising across the globe with changing customer demand andAttestation of information provided by trading partners andcritical than ever due to the rise in global

decarbonization-related incentives. The number of electric vehicles on the road

manufacturers using digital signatures, and whether such attestations
can be verified by the recipients.

EV sales.

worldwide reached 16.5 million in 2021.2 The total number of EVs is projected toreach 700 million by 2050.3 According to the same report, “all automobile salesin Europe (86%), China (81%) and North America (78%) will predominantly be
EVs by 2050”. Although this shift to EVs will reduce net carbon emissions,

1

Arrinda, M.; Oyarbide, M.; Macicior, H.; Muxika, E.; Popp, H.; Jahn, M.; Ganev, B.; Cendoya, I. Application DependentEnd-of-Life Threshold Definition Methodology for Batteries in Electric Vehicles. Batteries 2021, 7, 12. https://doi.
org/10.3390/batteries7010012
2

Electric Vehicles – Analysis.” IEA. November 202, IEA. https://www.iea.org/reports/electric-vehicles.

3

Mackenzie, Wood. 2021. “700 Million Electric Vehicles Will Be on the Roads by 2050.” Www.woodmac.com.

February 8, 2021. https://www.woodmac.com/press-releases/700-million-electric-vehicles-will-be-on-the-roadsby-2050/.

4© 2023 MOBI. All rights reserved.

© 2023 MOBI. All rights reserved.

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used EV batteries can greatly impact the environment if not properly managed

repurposed, they often find their way into landfills. This disposal method not

past their first use.

only raises concerns of water and soil contamination but also escalates the riskof fires due to the presence of toxic and flammable materials within the batteries.

Note: For the purpose of this project, ‘EV battery’ is defined as any battery
specifically designed to provide electric power for the traction to hybrid or electricvehicles of L category as provided for in Regulation (EU) No 168/2013, and with

5.3 Current Regulatory Environment

a weight above 25 kg, or designed to provide electric power for the traction tohybrid or electric vehicles of M, N, or O categories as provided for in Regulation(EU) 2018/858. More specifically, batteries discussed in this document pertain
to lithium-ion batteries.

Recent regulation proposals andRecent regulation proposals and policymaking efforts in the EU, US, and Asia

policymaking efforts in the EU, US, andhave incentivized stakeholders in the battery market to identify responsible

Asia have incentivized stakeholders in thebattery market to identify responsible
parties for handling EOL and more.

Battery reuse and repurposing are also

The phases in an EV battery’s life cycle that generate the most emissions andimportant to achieve circularity and reduce

waste involve material sourcing, manufacturing, and end-of-life activities.

waste and resource depletion.

batteries more sustainably.
United States

reduce its environmental impact by increasing battery recycling such that raw

There are existing regulations in the US at the federal and state levels to regulatematerials can be extracted for the manufacturing of new EV batteries.4 Battery

activities that are relevant to the EOL of batteries, but there are currently noreuse and repurposing are also important to achieve circularity and reduce waste

holistic, overarching policies for batteries at their EOL, and it is ambiguous how

and resource depletion.

used LiBs are legally defined in terms of waste.8

A variety of recycling technologies for EV batteries exist today and more LiB-

responsible parties for EOL management,

focused recycling plants are being developed. However, only about 5% offactors.

methods of recycling (with higher recovery rates), and design and produce

According to the CalEPA, it is crucial to create a circular battery supply chain andLack of regulations, lack of clarity onhigh cost of recycling and geographicalparties for handling EOL, increase EV battery recycling, develop more efficientbatteries are being recycled.5 Lack of regulations, lack of clarity on responsible

In the US, used batteries are generally

In the US, used batteries are generally considered hazardous or universal

considered hazardous or universal waste,

waste, which are then bound to existing waste regulations. Regulations also

which are then bound to existing waste
regulations.

parties for EOL management, high cost of recycling, geographical factors (suchvary by jurisdiction. The most stringent regulations include the US federal
hazardous waste laws and regulations, which are related to the generation,
handling, storage, treatment, domestic or international transport, and disposal

as proximity to recyclers), and lack of economic incentives represent a sample ofof hazardous wastes.9 The US also lacks regulations on sharing traceability

the various obstacles to recycling.

information about batteries.

Material Sourcing

European Union

Mining of lithium, nickel, and cobalt — critical minerals in LiB production — is

The European Union has introduced a regulation aimed to increase EOL

detrimental to the environment and often associated with ethical concerns.

management of EV batteries and provisions for digital records of batteries.

Recycling

China

Another factor contributing to the

While other types of batteries, such as lead batteries, are mostly recycled

diminished recyclability of LiBs is the lack(approx. 99% of lead batteries are recycled), it is relatively more difficult andVehicle manufacturers are required

In China, the government established a traceability management platform tocostly to recycle LiBs, as they consist of hundreds of li-ion cells that needto provide technical support to thesetrack electric vehicle batteries throughout their lifetime in 2018.10

of design considerations for recycling in the
majority of EV battery systems.

dismantling to be recycled, which can be dangerous as the batteries containhazardous materials.6 Another factor contributing to the diminished recyclability

enterprises and are responsible for selling
batteries to a qualified handler for reuse or
recycling.

The government released a set of policies that place this responsibility on EV

of LiBs is the lack of design considerations for recycling in the majority of EV

and battery manufacturers or importers. Vehicle manufacturers are required tobattery systems.7 When these batteries are not effectively recycled, reused, or

provide technical support to these enterprises and are responsible for selling
batteries to a qualified handler for reuse or recycling. A unique code is attachedto every battery produced in or imported into China for use in EVs to allow for

4

Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2022. “Lithium-Ion Car Battery Recycling Advisory Group Final

Report.” CalEPA. 16 March, 2022, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2022/05/2022_AB-2832_

tracking and proper processing at the end of the battery’s first life.11

Lithium-Ion-Car-Battery-Recycling-Advisory-Goup-Final-Report.pdf.
5

Woollacott, Emma. “Electric Cars: What Will Happen to All the Dead Batteries?” BBC News, April 26, 2021, sec.

Business. https://www.bbc.com/news/business-56574779.
6“New Study Confirms U.S.’ Most Recycled Consumer Product - Lead Batteries - Maintains Remarkable Milestone:

99% Recycling Rate.” Battery Council International. July 12, 2023. https://batterycouncil.org/new-study-confirms-lead-

7

Melin, H. E., “The Lithium-Ion Battery End-of-Life Market -A Baseline Study.” n.d. World Economic Forum. https://

www3.weforum.org/docs/GBA_EOL_baseline_Circular_Energy_Storage.pdf.
8“Pathways to Achieve New Circular Vision for Lithium-Ion Batteries.” n.d. NREL. https://www.nrel.gov/news/

program/2021/pathways-to-achieve-new-circular-vision-for-lithium-ion-batteries.html.

batteries-maintain-remarkable-99-recycling-rate/.

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PARTIES RESPONSIBLE FORINFORMATION MANAGEMENT

Regulation proposals like those listed above

Regulation proposals and policymaking efforts like those listed above have

have introduced requirements to designate

introduced requirements for stakeholders to designate responsible parties forresponsible parties for handling mattersrelated to EV battery EOL management.

handling matters related to EV battery EOL management. Additionally, due
to the battery passport requirements included in the EU Battery Regulation,

Information Received from Trading Partners: Battery Manufacturers receive
information from cell manufacturers and material sourcing companies aboutchemical compositions, ethical sourcing, and recycled material contents.

6.2 EV Manufacturers (OEMs)EV Manufacturers produce EVs and install

EV Manufacturers produce EVs and install battery packs to vehicles in thebattery packs to vehicles in the assembly,

assembly, during which a battery pack with an identity (serial number provided

during which a battery pack with an identity
is assigned to the vehicle and the VIN.

stakeholders operating in the EU will be tasked with the responsibilityby the Battery Manufacturer) is assigned to the vehicle and the vehicle
identification number (VIN).

of managing comprehensive information about battery packs, materials,

Information Provided to Trading Partners: As per the EU battery regulations,components, and related data.

since OEMs are the ones responsible for “putting the battery to a market,”they will be held accountable for the information’s traceability and auditability.

The following list provides a summary of responsible parties in EV battery EOL
Information Received from Trading Partners: OEMs rely on information about

management and the information they typically provide to their trading partners.

battery composition and sourcing information provided to them by the pack
manufacturers and other suppliers.

6.1 Battery Manufacturers
Battery manufacturers assemble and produce battery packs for EV Manufacturers

6.3 Collection, Dismantling, and Sorting
Companies(OEMs). They may also be involved in cathode and cell manufacture. Each packcontains cells assembled into modules along with the battery management
system. Pack assembly is sometimes done by the OEM.
Information Provided to Trading Partners: Battery Manufacturers are responsible
for providing the battery’s bill of materials information to OEMs. They may

The tasks of collection and sorting may beCollection and Sorting Companies gather used batteries from designateddistributed among different companies inlocations and safely store them in warehouses. The tasks of collection and sortingsome cases and require proper training forsafe handling and storage of used batteries.

register the materials used in the batteries through open platforms. They label the

may be distributed among different companies in some cases and require proper
training for safe handling and storage of used batteries. These companies supply
used batteries to other companies involved in battery recycling/repurposing/individual packs with serial numbers, global unique identity, safety information,

reuse.

etc. They ship the packs, which means they must provide information about thebattery content to the transportation company.

Information Provided to Trading Partners: Collection, Dismantling, and Sorting
Companies can provide information about which packs they received/sorted weresent to which EOL company. However, they may argue that such information is
confidential and hence cannot be made public.

Courtesy of The Globe and Mail

6.4 Battery Recycling Companies
Battery Recycling Companies recycle

Battery Recycling Companies recycle material from used batteries throughmaterial from used batteries throughvarious mechanisms, such as pyrometallurgical and hydrometallurgicalvarious mechanisms.

processes, and extract critical minerals.
Information Provided to Trading Partners: Some recycling companies alreadymaintain a list of battery serial numbers that they recycle and provide a list backto the manufacturers or OEMs as proof of recycling.

9

US EPA, OLEM. 2015. “Resource Conservation and Recovery Act (RCRA) Regulations.” US EPA. August 18, 2015.

https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-regulations.
10“China Launches Pilot EV Battery Recycling Schemes,” Reuters, July 26, 2018, sec. Environment. Reuters.

https://www.reuters.com/article/us-china-autos-batteries/china-launches-pilot-ev-battery-recycling-schemesidUSKBN1KF375.
11

Ambrose. H., O’Dea, J. (2021). Electric Vehicle Batteries: Addressing Questions about Critical Materials andRecycling. February 11, 2021, Union of Concerned Scientists. https://www.ucsusa.org/resources.

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6.5 Battery Repurposing Companies

6.10 EV Dealers and Repair Shops

Battery Repurposing Companies repurpose

Battery Repurposing Companies repurpose used battery packs and/or modules

EV Dealers and Repair Shops receive

EV Dealers and Repair Shops receive requests from vehicle and fleet owners

used battery packs and/or modules forfor secondary purposes such as grid storage, and utility backups. They may

requests from vehicle and fleet owners to

to check and repair EV batteries. They may be involved in finding issues insecondary purposes such as grid storage,
and utility backups.

remove modules/cells from the original pack and reform them into a different packcheck and repair EV batteries.

for second use such as grid storage. They may assign a different serial number

module-level repairs.

for the new pack. However, they need to maintain a record of deprecation of theInformation Provided to Trading Partners: A dealer or repair shop may reportold serial number.

their findings to the OEM, which may ask the dealer or repair shop to ship thefaulty battery/module to it or the battery manufacturer.

6.6 Battery Swapping/Reuse Companies
Battery Swapping/Reuse Companies allow consumers to swap an old battery

6.11 EV Owners and EV Fleet/Rental Companies

with a new one. This use case has not gained much traction in large-form
batteries but has gained popularity for smaller batteries used in two-wheelers.
They may remove/repair modules/cells and put them back into the original pack.
They may have to update the battery composition but keep the same serial
number for the new pack.

the battery pack. Dealers and repair shops are not quite qualified to perform

As end-consumers, EV Owners and EV

As end-consumers, EV Owners and EV Fleet/Rental Companies monitor the

Fleet/Rental Companies monitor the

performance of EV batteries during regular usage. They need to know the state

performance of EV batteries during regularusage.

of batteries (new and old) to make vehicle buying/selling decisions. They may
inform the vehicle manufacturers that may ask the dealers to ship the faulty
battery/module to it or the battery manufacturer.

6.7 Battery Testing Companies
Battery Testing Companies provide

Battery Testing Companies provide battery testing and certification services,

battery testing and certification services,

ensuring energy storage technologies meet performance, reliability, and safety

ensuring energy storage technologies meet
performance, reliability, and safety criteria.

criteria.
Information Provided to Trading Partners: Battery Testing Companies perform
tests on cells and modules to determine SOH and SOC on behalf of repurposing/reuse companies and provide the certificate of test to the regulators.

6.8 Transport Companies
Transport Companies serve manufacturers and distributors to physicallytransport and store minerals, manufactured components, and battery packs.
Information Provided to Trading Partners: Provide information about the risks oftransporting used and waste batteries to local/national environmental regulatorsand insurance companies.

6.9 Government Regulators and Policymakers
Government Regulators and Policymakers

Government Regulators and Policymakers propose and enforce local andpropose and enforce local and national level

national level regulations concerning battery recycling to meet sustainability

regulations concerning battery recycling tomeet sustainability goals.

goals. For these stakeholders, traceability of the battery’s critical minerals is
important to align with the goals and long-term economic policies on reducing
reliance on mineral import.
Information Received: Verify claims of battery traceability provided by the pack
manufacturers, OEMs, and repurposing/reuse companies.
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COLLECTION, STORAGE, AND
TRANSPORT

07

7.2 Storage and Transport
Prior to reuse, repurposing, or recycling,

Storage companies, including scrap yards, store used/waste batteries gatheredbatteries may first need to be stored at aby the collection companies. Storage may happen at different stages of the

facility before shipping/transporting in bulk
to make transportation more cost-effective.

The entities collecting used batteries need information on the condition ofhave reached EOL due to the multiplicity of

individual batteries. This is especially critical to identify batteries with potential

possible ways that a vehicle/battery can be
returned or retired.

involved in the storage and logistics process of used batteries.
Safety is one of the most important aspects that impacts how used batteries arethermal events. It can be challenging to collect batteries that have reached EOL

stored and transported. EV batteries pose a significant electrocution risk when

due to the multiplicity of possible ways that a vehicle/battery can be returned or

handled incorrectly and the risk is higher for physically damaged batteries.15 EV

retired. Vehicles or batteries may be returned/retired in a dealership and OEMbatteries also pose a significant fire risk in storage and transportation. Facilities

network or outside such a network. There is uncertainty regarding returning/where EV batteries are stored and dismantled must take safety precautions,retiring EVs that are out of warranty and it is difficult to track what happens toincluding proper staff training and equipment.

out-of-warranty batteries at EOL.12
Depending on the batteries’ SOH and condition, eligible batteries are designatedfor second-life use or for recycling. LiBs are produced by a variety of manufacturers
employing different chemistries; recyclers and repurposing companies often do

A used EV battery may end up in

Ownership of vehicles that have reached EOL due to collision is usuallyunlicensed dismantlers where capturingtransferred to insurance companies, which are likely to sell the vehicles at

into the recycling, reuse, and repurposing
cycle becomes very difficult.

not know a given battery’s chemistry, capacity, or SOH.

A standardized and more accurate method

A standardized, reliable, and more accurate method of battery SOH reportingof battery SOH reporting can potentiallycan potentially help in addressing whether a given battery is used or whether

help in addressing whether a given battery
is used or whether it qualifies as waste to
be recycled.

difficult.				
Transportation of used/waste batteries is a crucial link that binds collection to
storage to further recycling/repurposing. It is also one of the costliest stages in

on SOH/temperature/physical deformities and sends the batteries to pertinent

EOL management. These high costs associated with transport generally stem

recyclers or repurposing/reusing companies.

from multiple factors, insurance rates for transporting hazardous materials
being one of the biggest drivers.

Information on a battery’s history and SOH at the collection stage is important
to determine whether the battery should be recycled, reused, or repurposed.13

7.3 Information Sharing Gaps

Knowing this information beforehand can help responsible entities streamline

material recovery process and determine how a given battery should be handled.
Lastly, information on safe handling should be made readily available in training
materials by the battery manufacturers.

(which are then responsible for sending batteries to a sorting, repurposing,where capturing into the recycling, reuse, and repurposing cycle becomes very

company may be a defining entity that separates used vs. waste batteries basedon battery chemistry is crucial for recyclers to increase the efficiency of theinsurance auctions. Whereas vehicles with minimal value are sent to scrapyards
or recycling facility). A used EV battery may end up in unlicensed dismantlers

it qualifies as waste to be recycled after the sorting process. Hence, the sorting

the EOL management process and ensure safety in battery handling. Information

first need to be stored at a facility before shipping/transporting in bulk to maketransportation more cost-effective.14 There is a complex network of companies

7.1 Collection and Sorting
It can be challenging to collect batteries thatused battery’s life cycle. Prior to reuse, repurposing, or recycling, batteries may

Collections companies typically do not

Collections companies typically do not know the manufacturer, composition, or

know the manufacturer, composition, orinternal state of batteries before collecting them from various sources (such as

internal state of batteries before collecting
them from various sources. Sorting or

automotive dealers, individuals, etc.) Their primary responsibility is to gather

storage companies can create records ofthe used/waste batteries and bring them to a sorting company location. Hence,batteries received using the serial numbers

collections companies cannot provide reliable battery information to sortingfrom the battery labels.

companies.
Sorting companies are charged with segregating batteries based on
manufacturer, weight, type, etc. The sorting may also happen at the storage

12

Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2022. “Lithium-Ion Car Battery Recycling Advisory Group

Final Report.” CalEPA. 16 March, 2022, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2022/05/2022_AB2832_Lithium-Ion-Car-Battery-Recycling-Advisory-Goup-Final-Report.pdf.
13

Sarmah, Sudipta Bijoy, Pankaj Kalita, Akhil Garg, Xiao-dong Niu, Xing-Wei Zhang, Xiongbin Peng, and Dipanwita© 2023 MOBI. All rights reserved.

companies can create records of batteries received using the serial numbers fromthe battery labels. In most cases, sorting and storage companies do not reportsuch information to storage facilities, transport companies, disassemblers, orBhattacharjee. 2019. “A Review of State of Health Estimation of Energy Storage Systems: Challenges and Possible

recyclers. Transport companies also may not know the state of the batteries

Solutions for Futuristic Applications of Li-Ion Battery Packs in Electric Vehicles.” Journal of Electrochemical Energy

they are moving.

Conversion and Storage 16 (4): 040801. https://doi.org/10.1115/1.4042987.

12

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REUSE AND REPURPOSING OF USEDBATTERIES

08

8.2 State of the PracticeThere are three main steps involved in EV battery repurposing:16

8.1 Definitions»

Testing cells for performance,»

Removing packs and cells, and»Reconfiguring for second-life applications.

Used batteries that are not waste and have

Used batteries that are not waste and have remaining capacity in terms ofremaining capacity in terms of performance

performance can be either repurposed or reused. If there is enough SOH and

These metrics will determine suitable

Testing: Testing gauges the performance metrics of the battery, like the SOH,

there is no physical damage or potential for thermal events, then a battery cansecond-life use cases for a given battery orcell temperature. These metrics will determine suitable second-life use cases

can be either repurposed or reused.

be repurposed for different uses such as in a stationary energy storage system.
In reuse, the battery will be repaired by replacing damaged cells/modules orgroup of batteries

for a given battery or group of batteries. The closer the match, the better the
restored battery will perform.

other hardware components and putting them back into the original battery
pack. The image below shows a simple flowchart of how a battery is deemed
fit for repurpose or reuse.

There are two broad categories of SOH estimation methods for EV LiBs:17
Experimental methods

According to the EU Battery Regulation:1

results in parts or the complete battery thatis not a waste battery”

directly measure capacity by discharging and charging and»measure certain proxy parameters, such as impedance
and internal resistance, using laboratory devices such as

Repurposing
Repurposing means “any operation that»spectroscopy.

Repurposing means “any operation that results in parts or thecomplete battery that is not a waste battery, being used for a

Model-based methods

different purpose or application than the one that the battery

are based on physical equations and curve fitting, machine learning

was originally designed for.”algorithms.

Remanufacturing
Remanufacturing means any technicalRemanufacturing means “any technical operation on a used

operation on a used battery that includes

battery that includes the disassembly and evaluation of all its

the disassembly of all its battery modules

battery modules and cells and the use of a certain amount ofand cells and the use of a certain amount.

2

battery cells and modules, new, used or recovered from waste,
or other battery components, to restore the battery capacity toat least 90% of the original rated battery capacity, and where
the state of health of all individual battery cells is homogeneous,
not differing more than 3% from one another, and results in thebattery being used for the same purpose or application than the
one for which the battery was originally designed.”

14

Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2022. “Lithium-Ion Car Battery Recycling Advisory Group

Final Report.” CalEPA. 16 March, 2022, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2022/05/2022_AB2832_Lithium-Ion-Car-Battery-Recycling-Advisory-Goup-Final-Report.pdf.
15

Bisschop, Roeland, Ola Willstrand, and Max Rosengren. 2020. “Handling Lithium-Ion Batteries in Electric Vehicles:

Preventing and Recovering from Hazardous Events.” Fire Technology 56 (6): 2671–94. https://doi.org/10.1007/
s10694-020-01038-1.

14© 2023 MOBI. All rights reserved.

16“Battery Reuse: A Second-Life for Electric Vehicle Batteries Background Information for the California Lithium

Battery Recycling Advisory Group.” May 27, 2020, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2020/07/
Lithium-ion-Work-Group-Ambrose_LIB-AG-Meeting-Materials-5-27-20_a.hp_.pdf.
17

Noura, Nassim, Loïc Boulon, and Samir Jemeï. “A Review of Battery State of Health Estimation Methods:

Hybrid Electric Vehicle Challenges.” World Electric Vehicle Journal 11, no. 4 (2020): 66. https://doi.org/10.3390/
wevj11040066.
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Goes through to EV Battery EOL process again

From damaged vehicle andSOH* > 80%

EV Usage

SOH* < 80%
Reuse: Use the battery in EV again
End of Life

SOH* potentially > 80%

Direct Reuse
Second Life
1

Battery Collection

Repair/Refurbish/
Remanufacture

Sorting

SafetyAssessment

Repurposing: Use the battery in different application than EV
3
2

Mechanical &Electrical Testing

SOH* potentiallybetween 75% - 80%

Dismantled Repurposing
After dismantling, sort thecells/batteries by SOH*.

SOH* potentially < 75%

2

3

Dismantling

Reconﬁgure
Batteries

Second LifeTo Recycle

Direct Repurposing

1

Landﬁll

RecycleStack/Reconﬁgure
Batteries

Battery pack could have a few module/cell/BMS replaced or entirely reassembled from components with similar SOH
Testing the battery to determine if it is fit to be reused, repurposed, or recycled. This is also to sort batteries with similar
performances together for applications.

* SOH percentage thresholds are for illustration purposes only
SOH - State of Health
BMS - Battery Management System

This could include reconfiguring the module, cell arrangement, replacing BMS and packing, etc.

16

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There are also hybrid methods, which combine experimental and model-based

Neubauer et al. found that repurposing

Neubauer et al. found that repurposing costs can be as low as USD 20/kWh

methods.

costs can be as low as USD 20/kWh if

if vehicle diagnostics data are available to support used battery purchases.

vehicle diagnostics data are available tosupport used battery purchases.

It is economically impractical to replace faulty cells within modules, therefore

EV batteries are also usually high voltage

Removing the battery packs and battery cells. This can be challenging forand require safety training.

various reasons. Many current batteries are not designed to be taken apartby Mineta National Transit Research Consortium, available post-vehicle

and the OEMs have been designing the battery with different form factors andapplication batteries could range from 1.376 million to 6.759 million — an ample

chemistry. EV batteries are also usually high voltage and require safety training.

supply for repurposing.22

Stationary storage batteries can be used in

Reconfiguring the packs for second-life applications such as stationary storage.

a wide range of use cases like load sharing,More specially, stationary storage batteries can be used in a wide range of

backup power supply, and storing green
photo-voltaic system energy.

residential, commercial, and industrial use cases like load sharing, backup power
supply, and storing green photo-voltaic system energy. Batteries can be also

minimizing purchases of modules containing faulty cells is critical.21 As predicted

High-performance applications for electric

High-performance applications for electric vehicles (EVs) typically demand an

vehicles (EVs) typically demand an initial

initial capacity retention of 80% or higher, indicating that the batteries still retain

capacity retention of 80% or higher.

a substantial portion of their original capacity and value. Given the abundanceof available supply, the efficient utilization of the residual value present in theseused as backup power systems in residential or commercial buildings. Sincecostly battery components assumes critical economic significance. Furthermore,

renewable energies are by nature intermittent, being able to store energy isfrom an environmental perspective, ensuring the safe handling of materials,

critical to support their expansion and ultimately decrease the carbon footprint

particularly heavy metals like Nickel and Cobalt, is imperative due to their toxic

of the energy sector.
safety training.

nature. Second-life application of batteries also serves as a viable alternative toMany projects and experiments have been tested around the world from pilot torecycling techniques. It is estimated that batteries can be extended by at least

commercial facilities.

10 years, or potentially even longer, contingent upon the specific applications in•

direct battery recycling, affording the industry more time to enhance existing

which they are employed.23

General Motors partnered with residential energy providers to test thecost efficiencies and utility of the system using Chevy Volt LiBs.18•

8.3 Information Sharing Gaps

Toyota is planning to use retired batteries to power 7-Eleven stores inJapan. Toyota donated 208 hybrid battery packs with solar arrays to
Yellowstone National Park’s Ranger Station and Education Center toprovide sustainable power.19•

Daimler launched projects for stationary energy storage also. Their
Netherlands site has built a 2.8MWh system in 2018. Their recycling
plant in Lunen has a 13MWh storage system.

•

In California, B2U storage solution built an 8MWh system connected
to PV system and is expanding to 17MWh.20

Batteries usually arrive at third-party reuse

Batteries usually arrive at third-party reuse centers as enigmatic “black boxes,”

centers as enigmatic “black boxes,” making

making it challenging to access24 the essential information required to optimize

it challenging to access the essential
information required to optimize reusepractices.

reuse practices. In the context of information needed by reuse and repurposing
companies, they often encounter difficulties in obtaining readily accessible
data about battery design, chemistry, SOH, and usage history. These obstacles
frequently necessitate expensive testing procedures and limit their capacity tofine-tune the reuse processes.

A cost-benefit analysis was done independently for each of the three types ofpost-vehicle-application processing by the Mineta National Transit ResearchConsortium. Among the three types of processing, repurposing is a less welldefined application area that is profitable if the development cost is at most USD
83/kWh to USD 114/kWh, depending on research and development expenses.

18

Zhao, Yanyan, Oliver Pohl, Anand I. Bhatt, Gavin E. Collis, Peter J. Mahon, Thomas Rüther, and Anthony F.

21Neubauer, J., E. Wood, and A. Pesaran. Rep. Identifying and Overcoming Critical Barriers to Widespread Second Use

Hollenkamp. “A Review on Battery Market Trends, Second-Life Reuse, and Recycling.” Sustainable Chemistry 2, no. 1

of PEV Batteries. National Renewable Energy Laboratory, February 2015. https://www.nrel.gov/docs/fy15osti/63332.

(2021): 167–205. https://doi.org/10.3390/suschem2010011.

pdf.

19

Standridge, Charles R., and Lindsay Corneal,. Rep. REMANUFACTURING, REPURPOSING, AND RECYCLING OF

22

Standridge, Charles R., and Lindsay Corneal,. Rep. REMANUFACTURING, REPURPOSING, AND RECYCLING OF

POST-VEHICLE-APPLICATION LITHIUM-ION BATTERIES. Mineta National Transit Research Consortium, June 2014.

POST-VEHICLE-APPLICATION LITHIUM-ION BATTERIES. Mineta National Transit Research Consortium, June 2014.

https://transweb.sjsu.edu/sites/default/files/1137-post-vehicle-Li-Ion-recycling.pdf.

https://transweb.sjsu.edu/sites/default/files/1137-post-vehicle-Li-Ion-recycling.pdf.

20

Ambrose, Hanjiro. “Lithium-Ion Car Battery Recycling Group Meeting Minutes May 27, 2020.” https://calepa.ca.gov/

23

Ambrose, Hanjiro. “Lithium-Ion Car Battery Recycling Group Meeting Minutes May 27, 2020.” https://calepa.ca.gov/

wp-content/uploads/sites/6/2020/07/Lithium-ion-Work-Group-Ambrose_LIB-AG-Meeting-Materials-5-27-20_a.hp_.

wp-content/uploads/sites/6/2020/07/Lithium-ion-Work-Group-Ambrose_LIB-AG-Meeting-Materials-5-27-20_a.hp_.

pdf. Accessed May 14, 2023.

pdf. Accessed May 14, 2023.
24

Tankou, A., Bieker, G., Hall, D., “SCALING UP REUSE AND RECYCLING OF ELECTRIC VEHICLE BATTERIES:ASSESSING CHALLENGES AND POLICY APPROACHES - WHITE PAPER,” February 2023, https://theicct.org/wpcontent/uploads/2023/02/recycling-electric-vehicle-batteries-feb-23.pdf

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Adding to the complexity, battery

Adding to the complexity, battery manufacturers are continuously engaged in

manufacturers are continuously engaged

innovating their battery technologies to maintain competitiveness. This constantin innovating their battery technologies tomaintain competitiveness.

innovation contributes to the extensive diversity seen in battery configurations,09

RECYCLING OF WASTE BATTERIES

encompassing aspects such as design, shape, size, mass, and chemistry. This

9.1 Definition

diversity is a defining characteristic of the contemporary EV market.
Recycling of EV batteries involves the

Recycling of EV batteries involves theextraction of materials from waste batteries.

batteries. At present, recycling is the most viable option for an EOL battery thatextraction of materials from waste

For repurposing, although the companies

In order to maintain linkage between the first use and later use of the same

are not required to maintain the linkages,

battery in the case of reuse, the reusing company has to maintain in its system

can’t be reused or repurposed due to quality and safety requirements, economic

such identity linkage along with battery composition updates. For repurposing,feasibility, and geographic limitations (such as the lack of facilities or transport

although the companies are not required to maintain the linkages, the EU Battery

infrastructure needed.)the EU Battery Regulation requires suchlinkage to be maintained in the battery
passport system.

Regulation requires such linkage to be maintained in the battery passportsystem. 		

9.2 State of the PracticeSoon-to-be enacted regulations and other

Although the LiB recycling market is still in the early phases, it has massive

policy-making efforts around the globe

potential for growth as recycling can aid the critical material shortage orare pushing battery manufacturers andautomakers to use and/or produce moreenvironmentally sustainable batteries.

procurement issues that many battery manufacturers are facing today.
Additionally, soon-to-be enacted regulations and other policy-making efforts
around the globe are pushing battery manufacturers and automakers to use and/or produce more environmentally sustainable batteries.

Most recycling companies collaborate

The most common methods of recycling today are hydrometallurgical andwith recycling organizations or a recycling

pyrometallurgical methods. These can be done separately or in combination.25

program to ensure sufficient recycling
amounts and that certain guidelines or rules
are met.

Initially, a mechanical treatment takes place after the EOL batteries are sorted
and labeled for recycling. Most recycling companies collaborate with recyclingorganizations or a recycling program to ensure sufficient recycling amounts andthat certain guidelines or rules are met.
Meanwhile, some recyclers will only recycle until the “black mass” is obtained, atwhich point they will sell the black mass to other recyclers for further processing.
Black mass is made up of metal oxides in the battery and carbon. More thanhalf of the world’s recycling facilities are based in the US.26 They are trying totackle challenges with LiB recycling and commercializing new technologies forrecovering Lithium, Cobalt, and Nickel from spent batteries.

25

Chengetai Portia Makwarimba, Minghui Tang, Yaqi Peng, Shengyong Lu, Lingxia Zheng, Zhefei Zhao, Ai-gang Zhen,

Assessment of recycling methods and processes for lithium-ion batteries, iScience, Volume 25, Issue 5, 2022, 104321,
ISSN 2589-0042, https://doi.org/10.1016/j.isci.2022.104321.
26

IEA. 2023. “Global EV Outlook 2023 Catching up with Climate Ambitions.” https://iea.blob.core.windows.net/assets/

dacf14d2-eabc-498a-8263-9f97fd5dc327/GEVO2023.pdf.

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9.3 Closed-Loop Recycling

Batteries may be mechanically shredded

treatment allowing the organic compounds to thermally decompose while theonce packs have been discharged andClosed-loop recycling is needed to achieve

dismantled/disassembled.

CAM is maintained as solid residue) is an alternative method that can be used to

In a closed-loop recycling system, all of the materials used in a product or goods

long-term supply chain viability andcan ideally be recycled, and recovered materials can go into the manufacturing

dismantling/disassembly, which involves removing various components of theof the same type of product again. Closed-loop recycling is needed to achieve

battery such as casing reducing the battery to modules or cells.

sustainability.

deactivate the battery. After the battery has been deactivated, it may undergo

long-term supply chain viability and sustainability. Usually, products that canbe recycled in a closed loop or near closed-loop system are designed such that

Batteries may be mechanically shredded once packs have been discharged andthey can be easily recycled and materials can be recovered with high efficiency

dismantled/disassembled. Air classification, sieving, and magnetic separationor higher purity. For example, aluminum can recycling is considered closed-loop

are applied after shredding to sort the components of the shredded battery. The

recycling as the aluminum can go back into making more aluminum cans.
LiBs can be recycled in a closed-loop

LiBs can be recycled in a closed-loop system via direct recycling, where manysystem via direct recycling, where many

critical materials can be recovered. Although the process is still not ideal today,

critical materials can be recovered.

shredded materials are sorted into metal-enriched liquid, plastic fluff, and metal
solids. These are then further sorted to obtain black mass. Most of the aluminum,
copper, and/or steel casings are recovered at this step. The black mass contains
relatively high concentrations of Nickel, Cobalt, Lithium, and Manganese.30 These

there are direct recycling technologies with relatively high recovery rates. With

materials can be recovered from black mass via a pyrometallurgical process

the ongoing development and innovation in this field, it is plausible to assume

followed by a hydrometallurgical process, or directly through hydrometallurgicalthat direct recycling systems will increase the efficiency of closed-loop LiB

processes.

recycling in the future.27

Depending on the degree of mechanical processing, the amount and quality of

9.4 Open Loop Recycling
Open-loop recycling is also referred to

In an open loop recycling system, products or goods with similar compositions

as downcycling or reprocessing. Today,

can be recycled together or separately and the quality of recovered materials is

open-loop recycling is more common in LiB
recycling.

recovered materials vary (more complex treatment can yield a higher quality/
amount output.)

generally altered through heat, chemical reactions, or physical crushing. The key
difference is that the recovered materials usually go back into the manufacturing
process of a different product (with lower-quality material requirements). Openloop recycling is also referred to28 as downcycling or reprocessing. Today,
open-loop recycling is more common in LiB recycling. With ongoing regulatory
efforts to increase the rate of recycling and increasingly stringent guidelines onrecovery rates and quality, it is expected that open-loop recycling systems will be
improved and the industry as a whole will move towards closed-loop recycling.

Pyrometallurgical Recycling
In pyrometallurgical recycling, LiB modules

In pyrometallurgical recycling, LiB modules are smelted in a high-temperatureare smelted in a high-temperature furnace

furnace to make a concentrated metallic alloy. This alloy consists of nickel, copper,

to make a concentrated metallic alloy.

and cobalt, which then can be further extracted through a hydrometallurgicalrecycling process. Lithium, manganese, and graphite are lost into the slag
(depending on the battery composition). Lithium and manganese can beextracted and recovered from the slag through a hydrometallurgical process.31
Alternatively, the slag may be directly used in the construction industry.
Pyrometallurgical processes can achieve high recovery yields for cobalt, nickel,

9.5 Recycling Methods

and copper.32

Treatment
Treatment processes include mechanicalTreatment processes include mechanical and thermal processes to prepare

and thermal processes to prepare thethe battery for recycling. Depending on the battery and the recycling process,battery for recycling.

different steps may be applied. This subsection reviews some of the mostcommon methods. Generally, the first step in treatment is discharging anddeactivating the battery to ensure safety.29 Pyrolysis (high-temperature
30

Brunn, Michael. 2021. “Black Mass One of the Hottest Issues in Battery Recycling.” RECYCLING Magazine.

September 10, 2021. https://www.recycling-magazine.com/2021/09/10/black-mass-one-of-the-hottest-issues-in27“What’s the Difference between Open-Loop and Closed-Loop Recycling?” November 19, 2021, The Pro DesignGroup. https://theprodesigngroup.com/whats-the-difference-between-open-loop-and-closed-loop-recycling/.
28“Open-Loop vs Closed-Loop Recycling.” 2018. General Kinematics. March 27, 2018. https://www.generalkinematics.

com/blog/open-loop-vs-closed-loop-recycling/.

battery-recycling/.
31

Metals Society of China 32 (8): 2746–56. https://doi.org/10.1016/s1003-6326(22)65981-8.
32

29“Battery Carbon Footprint Rules for calculating the Carbon Footprint of the ‘Distribution’ and ‘End-of-life andrecycling’ life cycle stages” April 2023, Battery Pass. https://thebatterypass.eu/assets/images/content-guidance/

REN, Guo-xing, Cai-bin LIAO, Zhi-hong LIU, and Song-wen XIAO. 2022. “Lithium and Manganese Extraction from

Manganese-Rich Slag Originated from Pyrometallurgy of Spent Lithium-Ion Battery.” Transactions of Nonferrous“Battery Recycling Takes the Driver’s Seat.” March 13, 2023, McKinsey & Company. https://www.mckinsey.com/

industries/automotive-and-assembly/our-insights/battery-recycling-takes-the-drivers-seat.

pdf/2023_Battery_Passport_Carbon_Footprint_Rules.pdf.

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Hydrometallurgical Recycling
In hydrometallurgical recycling, impurities

In hydrometallurgical recycling, impurities of the black mass are removedof the black mass are removed throughthrough a chemical process called leaching and separation. The process flows

a chemical process called leaching andseparation.

10

PROPOSED REGULATIONS

of hydrometallurgical processes vary; however, they generally include leaching,
purification/separation, precipitation, and crystallization (or electrowinning).33

Various proposed regulations described

Various proposed regulations described below will require information sharing

Leaching involves dissolving the metals in the black mass via a leaching media.

below will require information sharing

about batteries between the supply chain members, regulators, and end-users

In separation/purification, metals are separated and purified via chemical
reactions. Then, metals are recovered from the solution through crystallization

about batteries between the supply chain
members, regulators, and end-users.

at an unprecedented level throughout the life of batteries. The following sections
summarize, at a high level, such information sharing requirements.

or ionic precipitation. To further increase the purity of lithium, nickel, manganese,and cobalt, solvent extraction can be applied.
Direct Recycling
Direct recycling generally involves a

Direct recycling generally involves a combination of pyrometallurgical andcombination of pyrometallurgical andhydrometallurgical processes.34 In this process, cathode materials are recovered,hydrometallurgical processes.

which then can be directly used in battery production, without having to be

10.1 European Union Battery Regulations
The regulation also requires labeling on

The revised EU Battery Regulation addresses many aspects of the LiB lifecycle.

automotive and industrial batteries to

Critically, this regulation requires OEMs to provide open access to information

indicate material content, quantity, andorigin.

about batteries with a capacity of 2 kWh or more36 to facilitate the handling ofbatteries and determine EOL application. The regulation also requires labelingbroken down into individual materials.35 Relatively, direct recycling offers

on automotive and industrial batteries to indicate material content, quantity, andsubstantial advantages environmentally, economically and in terms of safety.

origin.

There aren’t many commercially deployed direct recycling technologies yet but it•

is a promising solution to battery supply chain problems as the most expensive

Starting in 2027, batteries produced in the EU shall be labeled withand important component of the battery can be recovered and go into thethe manufacturer name, battery type, date of manufacture, presence of

manufacturing of new LiBs.

hazardous substances, and other information that facilitates recycling
or reuse.
•

9.6 Information Sharing Gaps
The recyclers then take possession of the

Recycling companies typically know the origin of the waste batteries as theybatteries and, if requested, provide proof ofarrive from sorting and storage facilities as well as directly from the OEMs or

recycling to the OEMs.

Documentation or certificate on change of ownership, technicalaspects, and status shall be required for repurposed and reusedbatteries.

•

EOL information shall be included by battery manufacturers tominimize waste and contribute to the reuse and recycling.

battery manufacturers. The recyclers then take possession of the batteries and,•if requested, provide proof of recycling to the OEMs. Recyclers can provide

Information on how batteries should be safely dismantled, transported
and recycled is also attached in a safety label on the batteries.

proof of recycling certificates to their customers on a batch basis rather than an•

individual battery basis, and must coordinate with their customers to provide

Manufacturers shall be required to disclose the environmental impactof batteries they produce.

such certificates on an individual basis. This is still challenging for recyclers,since they may extract minerals in batches that may include packs from different
OEMs or battery manufacturers.
The regulation mandates increased

Increased recycling and reuse is another key element in the regulation. The

recycling and reuse, setting rules forregulation defines general rules for extended producer responsibility andextended producer responsibility andrequiring stakeholders to annuallytheroles of relevant stakeholders/parties (such as producer responsibility

report on batteries recycled and materialorganizations). Producers, recyclers, and other parties (if any) defined under therecycling rates.

extended producer responsibility scheme will be required to annually report on
batteries handled/recycled and the recycling rates of the various materials.

33

Battery Pass. “Battery Carbon Footprint Rules for calculating the Carbon Footprint of the ‘Distribution’ and ‘End-of-life and recycling’ life cycle stages” April 2023. https://thebatterypass.eu/assets/images/content-guidance/pdf/2023_
Battery_Passport_Carbon_Footprint_Rules.pdf.
34

Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2022. “Lithium-Ion Car Battery Recycling Advisory Group Final

Report.” CalEPA. 16 March, 2022, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2022/05/2022_AB-2832_
Lithium-Ion-Car-Battery-Recycling-Advisory-Goup-Final-Report.pdf.

36

European Parliament legislative resolution of 12 July 2023 on the proposal for a regulation of the European

Parliament and of the Council concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending
35

Wei, Gaolei, Yuxuan Liu, Binglei Jiao, Nana Chang, Mengting Wu, Gangfeng Liu, Xiao Lin, et al. 2023. “Direct

Regulation (EU), 12 July 2023, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1542.

Recycling of Spent Li-Ion Batteries: Challenges and Opportunities toward Practical Applications.” IScience 26 (9):107676. https://doi.org/10.1016/j.isci.2023.107676.

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Meanwhile, waste management operators and recyclers will be required to report

10.2 US Treasury Section 30D Tax Credits

defined under the extended producer

to competent authorities for each year and Member State (where the batteries

responsibility scheme will be required

were collected): the number of waste batteries received for treatment; the

The United States Department of Treasury published a notice of proposed

number of waste batteries that began preparation for re-use; data on recycling

rulemaking with regards to the Federal income tax credit under the Inflation

efficiency for waste batteries; recovery of materials from waste batteries; andReduction Act of 2022 for the purchase of qualifying new clean vehicles,

the destination and yield of the final output fractions. EU Member States areincluding new plug-in electric vehicles powered by an electric battery meeting

required to publicly disclose this data, as outlined in Article 76, in aggregatedcertain requirements and new qualified fuel cell vehicles.37

to annually report on batteries handled/
recycled and the recycling rates.

form annually, in the format established by the Commission.
Annex 12 defines recycling requirements and the deadlines for compliance/
effective dates of compliance. Regulation demands that recyclers achieve theDepending on the year, the EV was put

The critical minerals and battery components requirement with respect to theinto service, the mineral requirement

battery from which the electric motor of a vehicle draws electricity is satisfied if

progressively increases from 40% to 80%.

the percentage of the value of the applicable critical minerals contained in suchbattery that wererecycling efficiency targets delineated in Part B and material recovery targets
delineated in Part C. The first requirements are related to storage and treatment•(before recycling) for EOL batteries to ensure safety and proper handling.
The recycling requirements increase to 80%

According to the regulation, 65% by average weight of lithium-based batteries

by average weight for lead-acid batteries

need to be recycled by 31 December 2025 (please refer to Annex 12 Part B

and to 80% by average weight for lithiumbased batteries by 31 December 2030.

which the United States has a free trade agreement in effect, or•

manner as prescribed by the Secretary).

The recycling requirements increase to 80% by average weight for lead-acid

Depending on the year, the EV was put into service, the mineral requirement

batteries and to 80% by average weight for lithium-based batteries by 31

progressively increases from 40% to 80%.

December 2030.

Recycling needs to achieve recovery rates of 90 % for cobalt; 90 % for copper;
90 % for lead; 50 % for lithium and 90 % for nickel by 31 December 2027. These
recovery targets increased to 95 % for cobalt; 95 % for copper; 95 % for lead; 80

recycled in North America, is equal to or greater than the applicable
percentage (as certified by the qualified manufacturer, in such form orof the EU Battery Directive for recycling targets for other types of batteries).

This is followed by Part C, which defines the target recovery rates for materials.

extracted or processed in the United States, or in any country with

The proposed guidance would provide the

The proposed guidance would provide the rules for determining compliance withrules for determining compliance with thethe critical minerals requirement, including a three-step process for determining

critical minerals requirement.

the percentage of the value of the applicable critical minerals in a battery that
contributes toward meeting the Critical Minerals Requirement.

% for lithium and 95 % for nickel by 31 December 2031.

•

In Step 1, the manufacturer would need to determine the procurement
chain or chains for each applicable critical mineral.

Lastly, used batteries can only be exported

Meanwhile, producers will have to increase the collected number of portable

outside the EU if the recipient’s battery

batteries by 45% by 31 December 2023, 63% by December 2027, and 73% bybattery would need to be evaluated to determine whether critical

December 2030. Lastly, used batteries can only be exported outside the EU if

minerals procured from the chain have been (1) extracted or processed

the recipient’s battery management is compliant with EU requirements.

in the US, or in any country with which the United States has a freemanagement is compliant with EU
requirements.

•

In Step 2, each applicable critical mineral procurement chain in the

trade agreement in effect, or (2) recycled in North America.
It is mentioned in the regulation that the targets for recycling efficiencies and•material recovery in Annex 12 may be revised at least every five years according

The third step would involve the calculation of the percentage of thevalue of qualifying critical minerals contained in a battery.

to market developments regarding the availability of minerals and technical andscientific development in battery/EOL technologies.

10.3 CalEPA Recycling Advisory Working Group
California Environmental Protection Agency (CalEPA) Lithium-Ion Car Battery
Recycling Advisory Group published an extensive final report in 2022 regarding
the recommended policies for handling batteries at EOL.38

37

DEPARTMENT OF THE TREASURY, 26 CFR Part 1, Section 30D New Clean Vehicle Credit, April 17, 2023, https://www.govinfo.gov/content/pkg/FR-2023-04-17/pdf/2023-06822.pdf
38

Kendall, Alissa, Margaret Slattery, and Jessica Dunn. 2022. “Lithium-Ion Car Battery Recycling Advisory Group Final

Report.” CalEPA. 16 March, 2022, CalEPA. https://calepa.ca.gov/wp-content/uploads/sites/6/2022/05/2022_AB-2832_
Lithium-Ion-Car-Battery-Recycling-Advisory-Goup-Final-Report.pdf.

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California Environmental Protection Agency

The advisory group, consisting of industry players, government agencies, andand no other party has taken possession of the battery. The auto manufacturer(CalEPA) Lithium-Ion Car Battery Recycling

academic groups, identified two policies that garnered major support: coreis also responsible for providing educational materials to the service and repair

exchange with a vehicle backstop, and producer take-back. It should be noted

entities as well as the customers. The responsibility of the auto manufacturer

that the recommended policies “complement, and do not replace, current

begins when they are informed that the battery can be handled and that it has

warranty regulations and programs that require the vehicle manufacturer toreached EOL. The responsibility is transferred to a repurposer if the battery isproperly reuse, repurpose, or recycle a removed EOL battery that is still under

repurposed.

Advisory Group published an extensive final
report in 2022 regarding the recommended
policies for handling batteries at EOL.

warranty.”
Currently, there is no requirement for any party to coordinate and pay thecollection, transportation, and EOL processing fees for out-of-warranty LiBs thathave been retired. Whether a battery gets recycled, reused/repurposed, or sent
to landfill is dependent on the economic value and feasibility, which results in

Recommended policies focus on clearly

Recommended policies focus on clearly defining responsibility in handling thedefining responsibility in handling theend-of-life of EV batteries and mitigating the barriers that prevent EV batteries

end-of-life of EV batteries and mitigating
the barriers that prevent EV batteries frombeing reused, repurposed, and recycled.

from being reused, repurposed, and recycled. The report points out that as EVs
are not being retired in large volumes yet, these are nascent markets, hence
policymaking needs to be iterative. Recommended policies also enable EOL EV

stranded batteries.

batteries to be sold to a third party without the requirement of a partnershipwith the vehicle OEM, through which the battery can be reused or repurposed.

There needs to be clearly definedThus, there needs to be clearly defined responsibilities for EOL management andresponsibilities for EOL managementtransfer of responsibility between responsible parties. The report also highlights

and transfer of responsibility between
responsible parties. The report also

the need to define what makes up proper recycling. EOL responsibilities include

Policies also incentivize the design of new

Policies also incentivize the design of new EV batteries for easy disassembly andEV batteries for easy disassembly andrecycling. Both policies are promising solutions to address EOL management

recycling.

highlights the need to define what makes

battery re-labeling for identifying the responsible party in a reuse or repurposing

up proper recycling.

scenario; setting up reverse logistics to transport batteries to recycling hubs;

for battery and vehicle OEMs, which can be reflected onto customers as higher

coverage of recycling costs; and documentation of recycling if necessary.

costs for EVs. This can also negatively impact EV adoption. In the event that aof out-of-warranty batteries. Disadvantages include potentially higher costs

battery or vehicle OEM goes out of business, it could create a lack of responsible
Based on existing policies for differentCore Exchange with a vehicle backstop policy gathered the highest support

vehicle parts and industry standards, thisof 93% among the stakeholders polled for the report. Based on existing

policy defines responsibility under threepotential circumstances: recycling, reusing,and repurposing.

parties to manage the EOL of EV batteries and result in stranded batteries.

policies for different vehicle parts and industry standards, this policy defines
responsibility under three potential circumstances: recycling, reusing, andrepurposing.
•

When a battery or any module or cell needs to be replaced before avehicle reaches end-of-life, a core exchange program defined by the
EV battery supplier shall be used. The party removing the battery shallmake sure that it is reused, repurposed, or recycled properly. The party
selling an EV battery shall track via a core exchange program whether
the used battery has been managed accordingly.

•

If a dismantler takes ownership of an EOL vehicle, then they shall be
responsible for making sure that the battery is reused, repurposed, or
recycled properly.

•

Vehicle manufacturers shall be responsible for making sure that thevehicle is appropriately dismantled and the battery EOL is handledcorrectly if there is an EV reaching EOL where an OEM-certified battery
is not acquired and removed by a licensed dismantler.

The auto manufacturer is also responsible

Producer take-back policy gathered the second highest rate of support (67%).

for providing educational materials to the

In this policy, the responsibility to make sure that the battery is properly reused,

service and repair entities as well as thecustomers.

28© 2023 MOBI. All rights reserved.

repurposed, or recycled at a licensed facility (at zero cost to the consumer) belongs
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CLOSING THE INFORMATION GAPS

11.3 Using Data Source Verification

The EU Roadmap on Raw Materials and Recycling points out the need forother battery-related state data sharing

development of battery SOH diagnosis protocols to be used for sorting andcompanies, end-users, and regulators.

for the battery manufacturers, OEMs, and other responsible entities to be able

able to demonstrate that the digital battery

The regulation also requires SOH andmanufacturers, EOL management

One of the critical requirements of proposed regulations (both EU and the US) isregulations is for the battery manufacturers,
OEMs, and other responsible entities to be

11.1 Standardizing Battery State Data Sharing

between battery manufacturers, vehicle

One of the critical requirements of proposed

data actually came from them.

the data and preferably register such events in a tamper-evident ledger.

classification of batteries at EOL for reuse, repurposing, or waste recycling.39
The regulation also requires SOH and other battery-related state data sharing
companies, end-users, and regulators.

11.4 Maintaining Persistent Battery Identity
The EU Battery Regulation also requires that a battery’s unique identifier mustthat a battery’s unique identifier must be

be linked to any new identifiers created due to repurposing or reuse and such link

linked to any new identifiers created due tochallenges were identified from various pilot-scale battery recycling plants andrepurposing or reuse and such link shouldbe persistent until the battery is recycled.

should be persistent until the battery is recycled. For example, if an EV battery
module is later repurposed as a home energy storage then the manufacturerof the storage battery has to ensure that the new unique identity it assigned is

Although the SOH data can be madeFor example, lengthy and costly processes are needed to determine battery

available using CANBus and OBD2

SOH after the first life. Lithium-ion batteries are produced by a variety ofsupply chain.

The EU Battery Regulation also requires

However, there are multiple challenges around sharing such data. Some of thesesecond-life energy storage projects.40

reporting the SOH data to the EV battery

regulators to be able to easily verify such a source, the industry needs a system
like a battery passport but also requires the responsible entities to digitally sign

between battery manufacturers, vehicle manufacturers, EOL management

interfaces, there is no standardized way of

to demonstrate that the digital battery data actually came from them. For thedigitally linked to the previous identity of the battery manufactured by an OEM.
This will require a common system by which the new manufacturer knows theunique identity of the battery, records such a link, and publishes the link for

manufacturers with different chemistries and algorithms (deemed proprietary)

regulators and the general public.

to estimate SOH. Although the SOH data can be made available using CANBusand OBD2 interfaces, there is no standardized way of reporting the SOH data to

11.5 Use of Global Battery Passport

the EV battery supply chain.
A standardized, reliable, and more accurate way of SOH and other battery statedata reporting can help in addressing these challenges.

Article 65 of the EU battery regulation

The role of global digital records of EV batteries and the need for a globallyprovides attributes that must be included

interoperable system for battery value chain members to access and manage

in such digital records and also provides
requirements for the implementation of adigital passport system.

such records is obvious. Article 65 of the EU battery regulation provides attributes
that must be included in such digital records and also provides requirements for11.2 Access to Battery State Data

the implementation of a digital passport system.42

Reuse and repurposing companies need

The parties involved in collecting/sorting/dismantling battery packs andWe also believe if the value chain members are compliant with the EU regulation,access to information on the battery’s SOH

modules need prompt information on the state of the battery, primarily SOH

it will facilitate compliance with the US Treasury’s regulations on EV tax credits

and temperature events. Reuse and repurposing companies need accessbecause the passport requirements of the EU are broadly scoped and the mineral

to information on the battery’s SOH to estimate the remaining lifespan andtraceability-related information can be used to assert compliance with the US

determine whether the battery is suitable for a second-life application.

Treasury’s proposed regulation.

to estimate the remaining lifespan anddetermine whether the battery is suitable
for a second-life application.

41

Byscanning the battery labels, these entities can access such information promptly
at a large scale so that they can properly store and segregate used vs. waste
batteries as well as safe vs. unsafe ones.

In order to facilitate the implementation of a global battery passport system,
MOBI recently published a guideline on building a decentralized system that we
believe will be compliant with the proposed EU and US Treasury regulations andmeet their objectives of circularity and sustainability of EV batteries.

41
39

European Commission, “ROADMAP on RAW MATERIALS and RECYCLING Prepared by Working Group 2.”EU

Roadmap on Raw Materials and Recycling.
40

analytics-and-diagnostics-how-big-data-makes-ev-batteries-smarter-increases-longevity-and-unlocks-second-lifeuse/#:~:text=The%20intelligence%20generated%20by%20analytics.

30© 2023 MOBI. All rights reserved.

Solutions for Futuristic Applications of Li-Ion Battery Packs in Electric Vehicles.” Journal of Electrochemical Energy
Conversion and Storage 16 (4): 040801. https://doi.org/10.1115/1.4042987.

Shell, Cassidy. 2021. “Battery Analytics and Diagnostics: How Big Data Makes EV Batteries Smarter, Increases

Longevity and Unlocks Second-Life Use ” January 25, 2021, Cleanteach Group.https://www.cleantech.com/battery-Sarmah, Sudipta Bijoy, Pankaj Kalita, Akhil Garg, Xiao-dong Niu, Xing-Wei Zhang, Xiongbin Peng, and Dipanwita

Bhattacharjee. 2019. “A Review of State of Health Estimation of Energy Storage Systems: Challenges and Possible

42

European Parliament legislative resolution of 12 July 2023 on the proposal for a regulation of the European

Parliament and of the Council concerning batteries and waste batteries, repealing Directive 2006/66/EC and amending
Regulation (EU), 12 July 2023, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1542.

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California Lithium Battery Recycling Advisory Group.” May 27, 2020, CalEPA. https://calepa.ca.gov/wp-content/uploads/

reuters.com/article/us-china-autos-batteries/china-launches-pilot-ev-battery-recycling-schemes-idUSKBN1KF375.

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Ambrose, Hanjiro. “Lithium-Ion Car Battery Recycling Group Meeting Minutes May 27, 2020.” https://calepa.ca.gov/wp-

govinfo.gov/content/pkg/FR-2023-04-17/pdf/2023-06822.pdf.

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