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The usage of “intermediates” according the REACH regulation is a current practice in the industry.
The objective of this paper is to document examples of metal compounds used in the battery industry and assessing their status as intermediates.
Recognizing the increasing importance for his members of the Lithium batteries, among others advanced rechargeable technologies, RECHARGE has adopted a new tag line description, clarifying the focus of its activities:
The Advanced Rechargeable & Lithium Batteries Association
This Technical guidance refers to the limitation at 30% for the transport of Li-ion batteries by air, as described in the ICAO Technical Instruction for the Safe Transport of Dangerous Goods by Air (2015-2016 Edition).
Guidance for the 30% SOC implementation
The new ICAO regulation requires a controlled state of charge (SOC) at 30% or less for the shipment of Li-ion batteries by air (UN 3480). This limitation is not applicable to batteries contained in or packed with equipment (UN 3481). This SOC information shall be available for customers, enforcement agencies, freight forwarders, airlines and other entities upon request….
Due to the diversity, complexity and constant evolution of the composition of batteries and the wide range of composition observed, it will be justified to include some mirror entry classifications (both hazardous and not hazardous).
The European Battery Industry, represented by the co-signatories of this letter, invites the Commission and the Competent Authorities to establish, together with all concerned stakeholders, a methodology to properly classify waste batteries and mixtures of various types of waste batteries in the List of Waste and to assess the overall impact and consequences
In recent years there has been growing concern about the effectiveness of applying the EU
chemical regulation REACH’s Authorisation scheme to substances that are exclusively
handled in the workplace. In fact, the REACH Authorisation procedure has been considered
for such substances despite the fact that there were no identified risks outside the workplace
that would require further risk management measures. We believe that the authorisation
should not be considered as the preferred option when potential risks can be more
effectively addressed by workplace-specific legislation.
This report demonstrates how advanced rechargeable batteries play an interactive role in people’s daily life, and how these developed technologies do contribute to the societal issues of climate change, clean energy, raw material usage, and efficient resource management, including recycling at end-of-life.
With the market development of new rechargeable battery technologies offering longer service life and the possibility to be used to power other applications that the one they were designed for originally, the “re-use” or the “second use” of rechargeable batteries has been proposed to enhance their service life and/or to optimize their cost/performance ratio…
The industry express his concern relative to the Commission update proposal, particularly on the following points:
The European Commission has selected RECHARGE to develop the Product Environment Footprint for rechargeable batteries in an advanced pilot phase.
Out of 90 proposals, RECHARGE’s proposal has been retained with 11 other projects that will be part of the first set.
Initiated by the European Commission, the Product Environmental Footprint (PEF) is a Life Cycle Assessment (LCA) based method to calculate the environmental performance of a product. Through this project, RECHARGE aims to develop the applicable criteria to the environmental performance of batteries in selected applications, that can potentially be translated to the overall rechargeable battery sector. RECHARGE intends to develop the methodology of the environmental impact evaluation for rechargeable batteries based on the PEF guidance document, as well as selected Environmental Performance Criteria which are based on information accepted and recognised on an international basis by the battery industry and other stakeholders. Finally, the PEF pilot phase provides an opportunity to harmonise the rules for environmental labelling of the batteries.
The European Association of Advanced Rechargeable Batteries
168 av. De Tervueren, box 3
B-1150 Brussels, Belgium
Tel. + 32 2 777 05 60
Fax + 32 2 777 05 65