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There are endless possibilities when it comes to commercializing second-life EV batteries in a safe and sustainable manner. Although navigating the circular value chain and the corresponding legal obligations may feel like uncharted territory, fear not.

The EU's New Battery Regulation proposes a solution called Extended Producer Responsibility (EPR), which holds producers accountable for collecting and managing the disposal of their end-of-life batteries. Sounds straightforward, right?

Well, not quite. Because all participants are both a consumer and a producer in a circular economy, this new regulation is not as simple as it seems:

“(76a) Extended producer responsibility should apply to economic operators placing on the market a battery that results from preparing for reuse, preparing for repurpose, repurposing or remanufacturing operations […]” (pg 50).

Proper transfer of responsibilities between the market participants is a key enabler for circularity and comprises one of the three independent components that must always be considered when trading used li-ion batteries: Possession, Responsibility, and Ownership (we call it PRO).

How PRO influences each participant is different for everyone but the Venn Diagram at the top of this page should give a good overview.

To transfer Possession, the batteries need transportation. To transfer Responsibility, the participants need EPR release forms. To transfer Ownership, the participants must agree on a price to buy used EV batteries.

This may sound easy for most participants, from small car dismantlers to global car manufacturers, but they could find it very difficult and costly to correctly manage a clear and auditable transfer of PRO.

These challenges slow down the speed of change towards the formation of a circular economy. They hinder the growth of the innovative circular ecosystem, which in turn directly slows down the wider transition to a sustainable society.

At Cling Systems, we are experts in PRO transfer management. Our mission is to ensure compliant and efficient end-of-life management of batteries, maximizing value extraction through second-life use and recycling.

If you are part of the circular value chain of batteries, access our Cling platform here and don’t hesitate to reach out to discuss ways of collaborating towards a society we can be proud of.

And if you want to delve deeper into the topic of ownership and control of EV batteries, don't miss our previous article from November 2022.

Thanks for reading.

Selected insights
On Battery Passports - Circularity Secured or a False Dawn?
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Behind the Scenes: The Intricate Logistics of Battery Circularity
The blog addresses the complexities of handling end-of-life lithium-ion batteries, noting safety regulations and paperwork hurdles. It highlights efforts by transportation providers to streamline processes and stresses the importance of a digital infrastructure for circular battery value chains, with Cling Systems contributing.
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Extended Producer Responsibility, Producers, and Economic Operators = A whole greater than the sum
In this latest blog, co-authored by NORMA Advokater and Cling Systems, the meaning and consequences of EPR.
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