Materials / product legislation
Batteries are made of various systems (cathode, abode, electrolyte, separating media, BMS (Battery Management System), external casing, etc.
Each of those sub-systems are made of various materials (LiCoNi oxides, plastics, graphite…).
A battery as such is also a product subject to some pieces of legislation.
The production and placing on the market of those materials or subsystems or batteries are subject to a variety of legislations (product safety, REACH, CLP, … just to name a few).
EBRA is only involved with those legislations because they also apply to the recycled outputs of the battery recycling process (if re-used for manufacturing new batteries or other uses in the wider industry.
Here is a brief summary of the various obligations:
For recycled chemicals used again in the industry
Registration under REACH (although if some conditions are fulfilled, a recycler may enjoy an exemption to the registration step - Art 2.7.d of REACH).
The CLP regulation (with a SDS and an exposure scenario per use identified if so required).
SVHC management: there is a list of more than 200 substances of very high concern for which additional duties are imposed (notification, communication in the supply chain, etc.).
Restriction or authorisation regimes under REACH (for some very specific substances - there is no such substances included in batteries to our knowledge).
For products
Product safety regulations
SVHC management and SCIP database