Development of calculation rules for the separate collection of portable and light means of transport batteries in the proposal for a Regulation concerning batteries COM(2020) 798/3
This study provides the technical background to consider the setting of a collection target for batteries powering light means of transport (LMT), in the light of the evolution of their market share. This work contributes to the preparation of the implementation of the draft Battery regulation proposed in December 2020, especially concerning collection provisions for waste portable batteries.
The assessment of a possible definition of batteries in LMT products, their potential market evolution and various options for modernising the collection targets for waste portable and LMT batteries aims to support decisions in the ongoing legislative process. Due to the complexity of the topic and in order to disentangle various factors mutually affecting both the definition of LMT and the collection target, a structured reasoning is hereby proposed supporting the decision process, substantiated by a parallel quantitative assessment.
Regarding the definition of LMT products and their categorisation, 4 consecutive questions are formulated and then answered in the form of decision options with documentation related to:
i) The need for a dedicated collection category;
ii) The basis for possible definitions, e.g. related to function, weight and/or capacity;
iii) Definition of limit values and;
iv) Whether revision and update procedures would be required.
A similar approach is taken following a second set of 4 consecutive questions related to:
v) The need for an alternative collection target basis;
vi) Alternative target bases, e.g. related to placed-on-market and/or waste generation potential;
vii) Possible target levels, e.g. 65% of placed-on-market in 2025, 70% in 2030, and;
viii) The need for a future revision or not.
Based on the evaluation of various options and forecasting of various market scenarios, it is concluded that due to increasing sales of rechargeable and LMT batteries, plus potentially more durable primary batteries as well, there will be a growing discrepancy between the placed on the market (POM) volumes and the waste volume becoming available later. This means that the currently proposed POM based collection target, based on 3 preceding years of sales, will not be ‘steadily ambitious’, but disproportionally high for the years 2025 and 2030 when the newer target levels are respectively set at 65% and 70%. Reversely, in later years it will become disproportionally low. In short: the more dynamic the future market of LMT and portable batteries, the more reason to consider an available for collection (AfC) based target that more accurately reflects actual waste battery volumes.
By combining the most logic and preferred outcomes of each of the 8 key questions mentioned above, the following 3 combinations are derived, representing different ambition levels for substantiation of an alternative collection target definition, as presented here:
• The ‘base combination’ applies in case no additional category would be created for LMT batteries. In this case, it is recommended to classify as portable batteries all those batteries used in non-type approved LMT products, like small personal light electric vehicles (including monowheels, hoverboards, unicycles, e-scooters, e-bikes including those with throttles (L1e-A), plus those batteries used in LMT products in the categories L1eB and higher (including speed-pedelecs and 2-wheeled e-mopeds), with a weight below 8 kg. Subsequently, all larger batteries used in 3-wheeled e-mopeds and heavier would be classified as EV batteries. For the collection target itself, keeping the original ambition for the total volume would correspond with an AfC based target for portable (including LMT) batteries at 70% of AfC by 2025 and 75% of AfC by 2030. For this to be implemented, a common methodology would need to be developed. It is anticipated, no review clause may be needed, except possibly for developing implementation guidance for the deduction of non-collectable flows like export for reuse in the necessary monitoring protocols.
• The ‘future proof combination’ applies in case a modernisation of the categories is considered, with an additional in-between LMT category. In this case, it is possible to include heavier products compared to the ‘base combination’ that would otherwise not fit in the collection infrastructure for portable batteries. Therefore, all batteries in non-type approved wheeled vehicles and batteries in type approved L1e-L7e categories with an individual battery weight below 25 kg are recommended to be included. This effectively includes all e-bike and (larger) e-moped batteries as LMT batteries, while it excludes larger e-motorcycles (which will subsequently characterise as EV batteries). At the lower end, the threshold delineation from portable batteries can be made explicit by specifying wheeled toy batteries, not designed for use on the road, as portable batteries.
For the collection target, similar to the ‘base option’, 70% of AfC by 2025 and 75% of AfC by 2030 for both categories individually would correspond with the original ambition, with the alternative target basis reflecting the expected LMT waste battery volumes much more realistically. A revision clause and/or update procedure in this case might be wise to adapt the common methodology parameters and in case needed, the target level to the future development of the new ‘fifth’ category.
• The more ambitious ‘optimising collection’ combination is the same as the ‘future proof combination’ with an additionally differentiation of the collection target to portable rechargeable and primary batteries individually. By disentangling them, the full benefit of potential of the AfC effort would be exploited by focusing the reporting and monitoring at the subcategory level. In the future, this would maximise transparency and focus on the environmental priorities related to portable rechargeable batteries with a relatively larger environmental footprint than non-rechargeable batteries. When ‘Option 3’ is selected, the risk of cross-subsidising collection of rechargeable and LMT batteries by relatively collecting more ‘less relevant’ primary batteries would be removed.
In summary, reasoned solely from the collection perspective and by taking into account the various market scenarios evaluated in this report, the main recommendation is a modernisation of the target basis to be converted from a POM based target to an AfC based target. For both ‘Option 2’ and ‘Option 3’ with a new fifth category for LMT, some additional administrative burden will occur for monitoring and reporting. In case of adopting an AfC based approach, the collection schemes indicated willingness to timely develop the monitoring and reporting procedures as well as research support to substantiate the parameters for the necessary common methodology.
Finally, with an in-between LMT category, there is an additional possibility to align other non-collection requirements to the distinctive character of LMT batteries, such as extending certain relevant sustainability, safety and information requirements, currently being proposed (solely) for portable and/or EV batteries. It is recommended to further analyse such potential benefits for the newly defined ‘fifth’ category in the ongoing legislative process.
HUISMAN Jacob;
BOBBA Silvia;
2021-07-01
Publications Office of the European Union
JRC125615
978-92-76-39084-8 (online),
978-92-76-39442-6 (print),
1831-9424 (online),
1018-5593 (print),
EUR 30746 EN,
OP KJ-NA-30746-EN-N (online),
OP KJ-NA-30746-EN-C (print),
https://publications.jrc.ec.europa.eu/repository/handle/JRC125615,
10.2760/64633 (online),
10.2760/163961 (print),
