End of life and collection duties

End of life duties for a battery begin when the battery becomes waste, and the record must show who collects it, who takes it back, and who receives it for treatment. Chapter VIII of Regulation (EU) 2023/1542 places duties on producers, producer responsibility organisations, distributors, and treatment operators, operating through national collection systems in each Member State. The duties differ by battery category, and the record must state the category, the place of collection, the collection route, and the date of handover. A battery that is stored, exported, or handed to an informal handler without a record leaves the formal system, and the file should show how that outcome was avoided or, where it happened, how it was recorded.

End of life, in this record, means the stage at which a battery is discarded, becomes waste, or is removed from its first application for treatment, reuse, repurposing, or recycling. Collection means the gathering of waste batteries through a system set up for that purpose.

What is the legal frame for this stage?

End of life collection is not a single event at the end of a battery life. Articles 59 and 60 should be read with the definitions in Article 3, because the category of the battery decides which collection and treatment duties apply. A producer responsibility organisation arranging collection from retail take back points needs to know the category before any other check, since a portable battery, an LMT battery, an EV battery, and an industrial battery follow different routes. A retail take back point that receives portable batteries should log the date, the quantity by category, and the collector who removed the batteries, so the quantity can be traced to treatment.

How are handovers recorded?

For end of life collection, the handover record should also state the condition of the battery, the reason for transfer, and any safety information passed with it. Collection records, take back logs, and handover notes should be retained for each transfer, including consignment notes where waste law requires them. A producer responsibility organisation arranging collection from retail take back points should check that quantities at receipt match quantities at dispatch, allowing for the measurement method stated in the record.

How are targets stated and checked?

For end of life collection, the relevant target may be a collection rate, a recycling efficiency rate, or a material recovery rate, and each target has its own calculation method, reference period, and chemistry scope. Collection from end users must be free of charge for the end user in the circumstances the Regulation sets out, and the record should state the arrangement that applies in the Member State of collection rather than assume one arrangement for all states. A producer responsibility organisation arranging collection from retail take back points should record the source of each figure and the date on which the figure was checked, using a dated snapshot where a figure can change.

How are safety and classification decided?

End of life collection may involve a battery that is damaged, swollen, leaking, or otherwise in a condition that changes handling, and the record should state the condition found, the test or inspection applied, and the decision that followed. A retail take back point that receives portable batteries should log the date, the quantity by category, and the collector who removed the batteries, so the quantity can be traced to treatment.

What belongs in the passport entry for this stage?

For end of life collection, the entry should show the stage reached, the operator responsible at that stage, the date of the stage, and a reference to the underlying evidence, without adding a claim about a later stage that has not happened. Collection records, take back logs, and handover notes should be linked by identifier, so the passport entry, the handover note, and the treatment record refer to the same battery. A producer responsibility organisation arranging collection from retail take back points should check that the passport entry is updated when the stage changes, and that an earlier entry is preserved in version history rather than overwritten without trace. Collection from end users must be free of charge for the end user in the circumstances the Regulation sets out, and the record should state the arrangement that applies in the Member State of collection rather than assume one arrangement for all states.

What stays open, and how is it followed up?

For end of life collection, open items may include a missing handover note, a pending test result, a facility report not yet received, or a delegated act not yet published that will set a method or a format. A producer responsibility organisation arranging collection from retail take back points should list each open item, name the owner, and give the next review date. A retail take back point that receives portable batteries should log the date, the quantity by category, and the collector who removed the batteries, so the quantity can be traced to treatment.

How is one collected battery followed to treatment?

Follow one waste EV battery from a dealer take back point to treatment. The dealer log records the identifier, the category, the condition, and the date. The collector receipt records the same identifier, the quantity, and the collection date. The carrier note records the transport date and the destination facility. The facility receipt records the identifier, the condition on arrival, and the treatment route. A worked file shows all four records with matching identifiers and dates in sequence, with no gap longer than the stated handling period. If one record is missing, the battery is shown as in transit or in storage, not as treated, and the missing record is logged as an open item with an owner.

Collection is complete only when the handover to treatment is recorded, and a collection log without a treatment handover describes a journey that has not ended.