National Electric Vehicle Strategy: consultation paper

This is a joint submission from the Australian Battery Industry Association (ABIA) and the Australian
Battery Recycling Initiative (ABRI) to the National Electric Vehicle Strategy – Consultation Paper.
ABIA and ABRI represent 80 members across the battery value chain, with that number growing as the Australian battery industry evolves. ABIA’s mission is to collectively ensure a trusted, transparent and sustainable battery industry in Australia. ABRI’s mission is to drive and expand a safe and sustainable battery circular economy.

ABIA and ABRI have a statement of collaboration to drive continuous improvement in battery quality, industry standards and further development of world class circular economy practices. This combines expertise and experience to deliver better outcomes for customers and industry by:
• Advocating for and driving product quality standards
• Strengthening safety and compliance
• Minimising environmental impacts throughout the battery life cycle
• Providing a strong and unified voice to government

Electric vehicle strategy to address consequential impacts of road transport electrification
ABIA and ABRI recognise that changing fuel efficiency standards and the resulting vehicle electrification will have substantial consequential impacts. The impacts for members are summarised in the table below and should be addressed as a core component of the strategy.

International jurisdictions are preparing for the consequential impacts of introducing EV policies and so should Australia. The challenge, even in jurisdictions with greater EV uptake than Australia, is that the implications of widespread adoption of EV batteries are still being learnt and worked through.
This requires an iterative policy approach to support impacted industries and recycling today – and flexibility in the policy approach to adapt to the challenges of tomorrow.

Market segment Aftermarket battery sales Recycling
Portable batteries e.g. • Step change in customer advisory
• Growth in battery
12 V car starter, role to support safety, product
recycling capability to
escooter, ebike and quality and servicing of new products
create feedstock for
mobility device • Unknown impact on business
new products
batteries operations and competition due to
• Development of
changing car designs, possibly limiting
manufacturing
who can change a 12v battery and
processes and
the potential life cycle of a 12v
potentially exportable
battery changing in an EV application
technology to support
reducing demand over time.
reuse, disassembly
High voltage batteries Not applicable
and recycling
built into vehicle

Data and information sharing is critical to support customers and secondary industries
To support industries, such as the battery aftermarket and battery recyclers, sharing of information to support a competitive customer service market, informed customer choice and end of life management will be crucial. This data includes information on battery performance through the battery management system, servicing needs, battery chemistry and disassembly.
Core elements of the EV strategy:
• Considers the need for differences in approach by battery application and chemistry.
• Analyses, and if necessary addresses, impacts of the timing and speed of transition on industries
that service the road transport sector.
• Underpins EV battery safe handling and management throughout the battery lifecycle for both
low and high voltage batteries. This includes information provision so all parties can make
informed decisions to support safe and sustainable battery purchasing, handling, disassembly
and recycling wherever they interact with the EV battery lifecycle.
• Prioritises EV batteries safely and sustainably becoming feedstock for new products, through
recycling, repurpose or reuse that optimises the best outcome for all parties such as:
o All batteries are recycled in Australia underpinned by a world leading battery recycling
sector and local technology
o Giving precedence to the development of commercial solutions
o Strengthening product safety at all stages of the supply chain
o Accessible product knowledge to support repair, re-use, and recycling
o Minimising costs and red tape where safe and sustainable to do so
o Consistency with policy developments and regulation overseas, such as producer
responsibility and battery tracking rules, to maximise and leverage existing opportunities
o Ensure urban, regional and remote areas can access battery recycling opportunities

Immediate no regrets actions to: improve safety and information for customers on battery quality
(particularly for mobility devices and portable batteries); and support recycling; are:
• Skills & Training - Supporting automotive industry adaptation through training on EV battery
servicing, maintenance and replacement.
• Standards/regulation - Introducing product quality standards, particularly for portable
batteries, for example through meeting international product and safety testing standards
• Standards/regulation - Strengthened lithium battery labelling standards particularly for
smaller, portable batteries which are handled by consumers.
• Data – identify data sharing needs that support customer focused outcomes and a
competitive service market and facilitate end of life management.
• Data - Nationally consistent fire incident reporting to share learnings from incidents and
support future data analysis.
• Data/regulation – Implementation of the national waste tracking system to improve data
collection and streamline business operations. This should include clarification of where
batteries for reuse and repurposing sit within this framework.
• Harmonised regulation to support safety, clarify and sustainability.

ABIA and ABRI offer their expertise to assist the Australian Government to support the EV Strategy development. For further information, please contact Katharine Hole, ABIA Secretariat, via email on secretariat@abia.org.au or CEO, ABRI on secretariat@batteryrecycling.org.au.

Yours sincerely
BY EMAIL
Katharine Hole
CEO, Australian Battery Recycling Initiative
Secretariat, Australian Battery Industry Association
Attachment 1 – ABIA & ABRI response to questions in the National Electric Vehicle Strategy – Consultation Paper

Questions ABIA & ABRI response
Q1 – do you agree with the ABIA and ABRI suggest three other objectives for consideration:
objectives and do you consider 1. Safety
they will achieve our proposed
2. Successful transition of industries servicing road transport battery needs
goals? Are there other
objectives we should consider? 3. Consistency with other policy priorities which support recycling, circular economy, critical technologies of national
interest and Defence’s Future Ready strategy
Safety – ABIA and ABRI members are acutely aware of the safety issues emerging with electric batteries and would strongly
encourage including safety as a goal. The safety issues and risks vary across the different user segments (such as e-bikes,
mobility devices, cars) and different chemistries. However, there are some common themes:
• Product quality, independent testing and existing international standards can play a role
• Education for safe charging and discharging practices and battery maintenance, particularly for batteries which are
easily removable and portable. The complexity of the integration of EVs with the home electricity system needs to
be explained in easily understandable terms. ABIA and ABRI are aware of rapidly emerging commercial relationships
in overseas jurisdictions between energy companies and EV OEMs to look at how electricity and EV sales can be
linked and/or how EV batteries can be repurposed for energy storage.
• Education around purchasing a second hand EV or repurposed/reused EV batteries is critical. This is likely to require
standards or guidelines, in particular transparency on matters such as “battery health”.
• Framework for managing damaged batteries which is fit for purpose to the battery application.
• Safe and sustainable disposal of used batteries relevant to the battery application. Solutions may vary depending on
the battery application, size, chemistry and logistics chain.
• Development of a framework for safe and sustainable battery reuse and repurposing.
Consequential industry impacts – The EV Strategy will have significant impacts on industries which are battery suppliers to
all sectors of the road transport sector (mobility, automotive and trucking) and battery recyclers. Therefore, it should
consider the consequences of the market transition on other business sectors.
In this context, the objectives should also consider successful economic (industry and market) transition to widespread EV
penetration and consider actions that will support this transition. The key battery sectors are:

Page 3 of 11
Questions ABIA & ABRI response
1. Automotive aftermarket battery product importers, distributors and retailers represented by the ABIA. Adaptation
of the automotive industry is critical to the livelihood of the current aftermarket service industry and to support
customer choice in a competitive market. This includes supporting a competitive market for servicing and
maintenance of EVs, which are significantly different to internal combustion engine vehicles.
2. The battery recycling chain from collection of used batteries through to physical recycling represented by ABRI and
where ABIA members are often involved in the collection of used batteries
ABIA and ABRI can work through the transition impacts when there is greater clarity around the likely policy levers the
Government is proposing to use and the timing for implementing these levers, such as fuel efficiency standards if this is
adopted.
For the battery recycling industry, whilst OEMs are reaching out directly to battery recyclers to explore opportunities for
end of life EV batteries and there are EV batteries going through to the recycling sector, the quantities are small. In 2022,
three lithium battery recycling start-up businesses joined ABRI. ABRI is aware of other companies who are also starting up
and/or exploring lithium battery recycling operations. This indicates the potential for recycling in Australia, including the
development of specific world class recycling technology that has the potential for export markets.
Recyclers are exploring and specialising in a range of solutions including developing hub and spoke solutions so that
batteries can be partially processed to reduce transport costs and safety risks and then fully processed at centralised
recycling facilities. The added challenge is the management of different and changing chemistries. These chemistries
continue to evolve.
Supporting end of life battery recycling requires solutions which deliver the best outcomes for all parties across the battery
value chain and deliver a circular economy taking into account factors such as:
• Prioritisation of the development of commercial solutions directly between counterparties as these are already
emerging across the supply chain including battery repurposing and directly with recyclers
• Minimisation of costs to consumers
• Consideration of what policy levers may be required to support early stage industry development until volumes
become commercial and/or support for recycling in regional areas
• Recognition of emerging global product stewardship obligations on OEMs and that these should not be duplicated
• Minimisation of red tape
• Design for repair/re-use/recycling
Questions ABIA & ABRI response
The batteries used in EV road transport are not homogenous, they differ by application, market distribution channels and
chemistries. While one size fits all policy approaches are preferable, differences in safety issues, chemistry, battery size and
economic factors with EV battery transport categories means that policy approaches will likely need to differentiate. Policy
differentiation by battery application for recycling, information and safety is being recognised and progressed in many
leading international markets.

In Australia, the EV Strategy should be seen as an industry development opportunity. ABRI has seven lithium-ion battery
recycling members at various stages of operation and development. There are already arrangements whereby electric
batteries are being sent to battery recyclers for processing albeit advanced materials processing, such as black mass
separation and metals recovery, is still evolving. Some battery chemistries, such as nickel metal hydride may be shipped
overseas for recycling as it is not commercial to develop recycling in Australia today. OEMs and ABRI members are exploring
future commercial recycling arrangements. The key challenges are many and include: the timing of volumes and capacity
needs; the confusing regulatory framework; and evolving understanding of best practice battery recycling as the industry, as
it is overseas, is nascent.
Consistency with other Government policy frameworks – it is critical that the EV Strategy works in parallel with other
Government policies and is not incongruent with these policies. For example, recycling is mentioned as part of the value
chain, but importantly, it closes the loop to create a circular economy and secures the supply chain. This has been
recognised in the US – where recycling is now a core part of their overall EV strategy. The Strategy EV Management Act (US)
aims to maximize reuse and recycling of end-of-life electric vehicle batteries in US Federal fleet vehicles.
A core component to support the goal to increase local manufacturing is to consider how the recovery of metals from black
mass in Australia can be achieved to support both value add in the metals manufacturing and the battery manufacturing
sectors. By not exporting black mass, we could increase the value add to the Australian manufacturing sector by 2.5-3 times.
Electric batteries are identified by the Australian Government as a critical technology as is advanced manufacturing and
critical minerals processing , battery recycling contributes to all these objectives to secure the supply chain.
2. What are the implications if A rapid uptake of EVs will potentially result in more jobs and new skills for the Australian economy. Australia needs to be other countries accelerate EV more than an “importer of product”. This is an opportunity to expand a nascent industry, in particular leveraging Australia’s uptake faster than Australia? world class capabilities as a researcher and developer of technology.
Slower EV uptake in Australia has consequential impacts for the battery recycling sector, including critical minerals recovery.
Batteries coming through for recycling will continue to trickle through at small volumes and the opportunity for critical
minerals value add will be limited resulting in metals recovery continuing to occur overseas. In this context,
Questions ABIA & ABRI response
• Other countries will develop infrastructure for the usage and end-of-life treatment of batteries, resulting in the
drain of opportunity locally, especially lost opportunity to recycle in the uptake phase, and low investment
confidence locally
• Less materials availability to support local advanced manufacturing development using rare materials from black
mass, with advancements made overseas
• Lower support in regional areas with volumes below a critical mass for infrastructure deployment
• Associated social opportunity cost e.g. jobs, industry hubs, knowledge centres, incubators
Ongoing reliance on imported products, and little buying power to influence battery standards in safety, performance,
longevity and repairability.
3. What are suitable indicators For the objectives proposed above, indicators could include: to measure if we are on track to • Safety achieve our goals and o Reducing the number of fire incidents, especially for micro and mobility devices objectives? o Improved industry understanding of safe handling and management of EV batteries across the battery life
cycle
o Improved industry practice in safe handling and management of EV batteries across the battery life cycle
• Industry transition
o Growth in local manufacturing in sectors supporting the EV industry (e.g. recycling, metal recovery,
chemical manufacturing for batteries)
o Competition in the automotive aftermarket sector, especially battery sales
o Successful industry transition of high street battery retail businesses
o Volume of batteries being recycled
o Success of complimentary industries to develop – including in technology areas such as metals recovery, fire
safety practices and battery chemistries
• Consistency with other government policy objectives
o Contribution of EV Strategy to achieving related policy objectives e.g. critical minerals recovery,
development of critical technologies?
4. Are there other measures by Managing insurance costs across the entire EV battery supply chain will be critical for supporting EV affordability from governments and industry that household insurance to service centres through to recyclers. Rising insurance cost for lithium batteries are proving a could increase affordability and challenge in the US, where there is wider uptake of EVs. The waste industry is facing insurance cost increases of 300 to 800%
Questions ABIA & ABRI response accessibility of EVs to help drive and similar figures are being informally reported in Australia. Government should consider how increased uptake of EVs will demand? impact the insurance market and consequently customer costs.
5. Over what timeframe should No comments at this time we be incentivising low emission vehicles as we transition to zero emission vehicles?
6. What information could help A business process map will highlight which industry segments interact with customers at different points of the EV supply increase demand and is chain and with which types of customers (household, commercial and heavy vehicles). This will then inform who is best
Government or industry best placed to inform customers about EVs, when they will need information and what type of information they will require.
placed to inform Australians The information requirements for purchasing a new EV, repurposing an EV battery, managing a damaged battery, providing about EVs? roadside assistance and other service, support and battery management functions will vary greatly as will the service
provider delivering that information.
7. Are vehicle fuel efficiency No comments at this time standards an effective mechanism to reduce passenger and light commercial fleet emissions?
8. Would vehicle fuel efficiency No comments at this time standards incentivise global manufacturers to send EVs and lower emission vehicles to
Australia?
9. In addition to vehicle fuel No comments at this time efficiency standards for passenger and light commercial vehicles, would vehicle fuel efficiency standards be an
Questions ABIA & ABRI response appropriate mechanism to increase the supply of heavy vehicle classes to Australia?
10. What design features should No comments at this time the Government consider in more detail for vehicle fuel efficiency standards, including level of ambition, who they should apply to, commencement date, penalties and enforcement?
11. What policies and/or No comments at this time industry actions could complement vehicle fuel efficiency standards to help increase supply of EVs to
Australia and electrify the
Australian fleet?
12. Do we need different No comments at this time measures to ensure all segments of the road transport sector are able to reduce emissions and, if so, what government and industry measures might well support the uptake of electric bikes, micro-mobility and motorbikes?
Questions ABIA & ABRI response
13. How could we best increase The consequences, particularly safety, and supporting consumers make informed choice about the overall financial the number of affordable implications of purchasing second hand EVs will be critical to supporting success in this area. Remaining battery life and second hand EVs? replacement costs will impact operating costs. An analysis of factors on the impacts of customers, the service industry and
other sectors involved in the handling of the second hand EVs including the list below should determine what actions are
required to safely and sustainably increase the number of affordable second hand EVs.
Areas which should be explored include:
• Warranties
• Insurance
• Information disclosure over different components of EV Life cycle:
o Labelling applies to all components of life cycle – dangerous and hazardous so anyone coming into contact
has key information
o Insurance implications and risks
o Purchasing new
o Purchasing second hand about the battery’s lifespan, history (e.g. has it been in an accident) and other
factors critical for informing a purchaser’s decision
o Digital tracking
o Accessible product information and diagnostics to support reuse and recycling
• Information on battery replacement costs and whether the existing battery can be resold for repurposing
• Safe operation for the service and maintenance sector
• Management requirements in the event the battery is damaged
• Tracking of the battery
14. Should the Government See Question 13 consider ways to increase the supply of second hand EVs independently imported to the
Australian market? Could the safety and consumer risks of this approach be mitigated?
Questions ABIA & ABRI response
15. What actions can Government could consider the following actions to support competitiveness and innovation: governments and industry take • Strategies to build on Australia’s mining metallurgical expertise to improve sustainable extraction of metals from to strengthen our recycled battery materials competitiveness and innovate
• Support for the development of secondary industries such as fire risk management, risk assessment, products and across the full lifecycle of the EV
services value chain?
• Assessment of strengths and weaknesses across the value chain to determine opportunity areas in bolstering local
capability and innovation
• Targeting regulation to risk areas only, and ensuring any regulation results in a fair and competitive landscape with
minimal additional effort overhead
• Incentivising design for repair, re-use and recycling
16. How can we expand our No comments at this time existing domestic heavy vehicle manufacturing and assembly capability?
17. Is it viable to extend No comments at this time
Australian domestic manufacturing and assembly capability to other vehicle classes?
18. Are there other proposals No comments at this time that could help drive demand for EVs and provide a revenue source to help fund road infrastructure?
19. What more needs to be ABIA and ABIA have identified no regrets action measures which could be undertaken immediately to improve EV safety and done nationally to ensure we sustainability. These could occur while the Australian Government develops the EV Strategy policy levers and then considers deliver a nationally how these can interact with measures to support industry transition, battery repurposing and recycling. No regrets
measures include:
Questions ABIA & ABRI response comprehensive framework for • Skills & Training - Supporting automotive industry adaptation through training on EV battery servicing, maintenance
EVs? and replacement.
• Standards/regulation - Introducing product quality standards, particularly for portable batteries, for example
through meeting international product and safety testing standards
• Standards/regulation - Strengthened lithium battery labelling standards particularly for smaller, portable batteries
which are handled by consumers.
• Data – identify data sharing needs that support customer focused outcomes and a competitive service market and
facilitate end of life management.
• Data - Nationally consistent fire incident reporting to share learnings from incidents and support future data
analysis.
• Data/regulation – Implementation of the national waste tracking system to improve data collection and streamline
business operations. This should include clarification of where batteries for reuse and repurposing sit within this
framework.
Harmonised regulation to support safety, clarify and sustainability. ABRI is collaborating with University of Sydney
on a project to stocktake existing regulation and consider what next steps should be taken.
20. How can we best make sure This requires ensuring the EV Strategy considers the broader impacts of transitioning the primary road transport energy all Australians get access to the source from fossil fuels to electric batteries. Considerations of the need for infrastructure, such as public charging stations, opportunities and benefits from to support EV transportation is well progressed. Equal work should now be focused on infrastructure needs to support the transition? collection, processing and recycling EV batteries, especially large batteries.
It is now time to look at the impacts and support a smooth transition for a range of other industries and their employees
that will be critical to underpinning the successful electrification of road transport in Australia. This includes aftermarket
battery sales, recycling and repurposing.
ABIA and ABRI offer their expertise to assist the Australian Government to inform the consequences on the road transport
support industry and its employees of policy options to accelerate EV adoption. ABRI is monitoring and working with
members and industry groups that are at the leading edge of battery recycling development, and as such should be seen as
a resource that Government can turn to. ABIA’s members are many of the leading battery manufacturers in the world, and
also have significant knowledge and resource that can be contributed to the discussion.