Second life and repurposing

Second life means a battery, module, or pack that has finished its first application is assessed and used again, either in the same kind of application or in a different application. Preparation for reuse keeps the battery in a similar application after checking and, where needed, repair. Preparation for repurposing and repurposing place the battery in a different application, such as an EV battery used for stationary storage. The distinction matters, because the Regulation treats the operations differently, the safety assessment differs, and the passport consequence differs. The record must name the operation, the new application, the assessment, and the operator responsible for the new life.

Second life is the general term for a further use after first life. Reuse means use in the same application after preparation. Repurposing means use in a different application after preparation. The scope covers batteries that had already been placed on the market before the operation.

What is the legal frame for this stage?

Second life and repurposing is not a single event at the end of a battery life. Articles 3 and 73 should be read with the definitions in Article 3, because the category of the battery decides which collection and treatment duties apply. A repurposer assessing EV modules for stationary storage 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. An EV pack removed from a vehicle should be tested for state of health, inspected for damage, and assessed against the stationary application, before any claim is made that the pack is suitable for that application.

How are handovers recorded?

For second life and repurposing, the handover record should also state the condition of the battery, the reason for transfer, and any safety information passed with it. The assessment report, safety checks, and the new application record should be retained for each transfer, including consignment notes where waste law requires them. A repurposer assessing EV modules for stationary storage 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 second life and repurposing, 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. A repurposed battery is treated as a new battery for placing on the market in the circumstances the Regulation sets out, and the record should state whether a new passport, a linked passport, or an updated passport applies, with the reasoning. A repurposer assessing EV modules for stationary storage 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?

Second life and repurposing 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. An EV pack removed from a vehicle should be tested for state of health, inspected for damage, and assessed against the stationary application, before any claim is made that the pack is suitable for that application.

What belongs in the passport entry for this stage?

For second life and repurposing, 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. The assessment report, safety checks, and the new application record should be linked by identifier, so the passport entry, the handover note, and the treatment record refer to the same battery. A repurposer assessing EV modules for stationary storage 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. A repurposed battery is treated as a new battery for placing on the market in the circumstances the Regulation sets out, and the record should state whether a new passport, a linked passport, or an updated passport applies, with the reasoning.

What stays open, and how is it followed up?

For second life and repurposing, 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 repurposer assessing EV modules for stationary storage should list each open item, name the owner, and give the next review date. An EV pack removed from a vehicle should be tested for state of health, inspected for damage, and assessed against the stationary application, before any claim is made that the pack is suitable for that application.

How is one pack assessed for a new application?

Assessment of one pack for stationary use starts with identity and history: the original passport, the state of health trend, the repair history, and the fault history. The pack is then inspected for damage, swelling, and leakage, tested for insulation and capacity under stated conditions, and assessed against the stationary duty, including cycle pattern and temperature. A worked file shows the pack identifier, the test results, the acceptance criteria, and the decision, with the assessor and date. A pack that passes capacity but fails insulation is rejected for second life, and the rejection reason is recorded, because a single failed safety check outweighs a passed performance check.

A second life claim stands only on the assessment behind it, and a battery without a dated assessment has no second life record, only a hope of one.