Tailor-made solutions for end-of-life EV-batteries (2022)

From the manufacturer to the dealer to the consumer. Back to the manufacturer, to the remanufacturer or the recycler, passing go and making another round. Lithium-ion batteries have a long journey to make in their lifetime, especially as they become more and more circular. Yet, with many people’s safety at stake, on every move and stop they need to be handled with the utmost care. That’s why lithium-ion batteries come with many regulations you need to consider, whether you are an importer, a producer or a handler. In the game of lithium-ion batteries, you win by playing safe!

Read on to discover the safety regulations and guidelines concerning lithium-ion batteries, in different phases of their life cycle.

Safety risks regarding lithium-ion batteries

Even though their battery chemistry is considered one of the safest, lithium-ion batteries still pose significant risks when not handled carefully.

The high-voltage nature of a lithium-ion battery comes with electrical hazards, such as short circuit, electrocution, electric shock or burning, whereas the chemical component inside the battery (the electrolyte) could leak out and cause intoxication or corrosion.

Tailor-made solutions for end-of-life EV-batteries (1)

Lithium-ion batteries are also prone to thermal runaway. If the temperature exceeds a certain threshold, the cells begin to vent hot gasses, which increases the temperature even further, and ultimately leads to ignition and fire.

These scenarios sound scary, but if everyone plays by the rules, it doesn’t have to come to that. The regulations concerning lithium-ion batteries help you feel safe, rather than sorry.

Safety regulations in every phase of lithium-ion batteries’ life cycle

The main regulations and guidelines for lithium-ion batteries are issued in three documents:


  • Batteries Directive 2006/66/EC: This is an EU-Directive that provides guidelines to the member states concerning the manufacture and disposal of batteries in the EU. Its aim is to improve the environmental performance of batteries and accumulators. This directive will soon be replaced with a new Regulation, that will level the playing field for all EU member states.
  • General Product Safety Directive (GPSD): The GPSD provides standards for product safety to protect consumers from potential hazards, by means of EN standards. The relevant EN standard for lithium-ion batteries is EN 60086-4. It serves as a reference point for specifications and technical solutions at the product design stage. Following EN standards is not mandatory but highly recommended.
  • ADR: The ADR is a UN-document, adopted by the European Union, which regulates the transport of hazardous goods over land. Following ADR rules is mandatory for transportation of lithium-ion batteries. The specific requirements for this type of battery can be found under article 2.2.9.1.7. All lithium-ion batteries are Class 9 and get the UN number 3480.

Depending on a battery’s condition and the phase in its life cycle, the risks and thus the safety rules vary.

What type of battery are you transporting? Let’s take a look at the different options and their ADR requirements.

New lithium-ion batteries

New batteries at the beginning of their journey are in their most stable state (with the exception of manufacturing defects), as they are charged up to 60 to 70% to ensure stability. The risks are relatively low, but caution is still required during transport and handling. Moving the batteries could pose minor thermal and mechanical risks, which is why all ADR requirements, including labeling and packing, are to be taken seriously at all times.


ADR labeling:
  • Class 9
  • UN 3480
  • “LI-ION BATTERY”
ADR packing:
packing instructions P903 or LP903

Used lithium-ion batteries for reuse

Battery Directive 2006/66/EC states that every battery producer has a take-back obligation. You can meet your obligation yourself or work with an organisation that takes care of this for you and decides what happens next. The most desirable options are re-use or remanufacturing, meaning that the battery maintains the status of ‘product’ (as opposed to ‘waste’). However in practice, recycling is currently still the most common option.

In case of reuse or remanufacturing, Li-ion batteries on their way to their new purpose are labeled and packed the same way as new Li-ion batteries.


ADR labeling:
  • Class 9
  • UN 3480
  • “LITHIUM-ION BATTERY”
ADR packing:

Undamaged waste lithium-ion batteries

When a used battery can’t be remanufactured or reused for a different purpose, it gets the ‘waste’ status and its ADR specifications change. An undamaged waste battery will be taken to the recycler, following these labeling and packing rules:


ADR labeling:
  • Class 9
  • UN 3480
  • “LITHIUM-ION BATTERY FOR RECYCLING”
ADR packing:

Damaged and defective lithium-ion batteries

Damaged lithium-ion batteries pose the biggest risk, as they are transported in a potentially highly unstable state. For packing, there is a distinction to be made between critical and non-critical damaged batteries. Damaged batteries in a critical state need to be packed in the safest way possible, to avoid accidents.


ADR labeling:
  • Class 9
  • UN 3480
  • “DAMAGED/DEFECTIVE LITHIUM-ION BATTERIES”
ADR packing:
  • Packing instructions P908 or LP904 if not critical
  • Packing instructions P911 or LP906 if critical
  • SP 376

Safe storage of lithium-ion batteries

After the batteries have safely arrived at their destination, sometimes they need to be stored for a while. Some countries have specific regulations concerning storage, others don’t. It is always advisable to check the legislation of the country in which you operate, and follow specific guidelines depending on the environmental permit, fire prevention rules and insurance. In general, we recommend you follow these storing tips:

Tailor-made solutions for end-of-life EV-batteries (2)

  • Store the cells in a dry, well-ventilated space, at the recommended temperature to maximise the batteries’ shelf-life.
  • Make sure the battery contacts can’t short circuit. Cover them with the manufacturer’s original cover or with electrical tape.
  • Avoid excessive vibration.
  • Avoid extreme temperatures and temperature changes.
  • Don’t place heavy objects on top of boxes containing lithium-ion batteries.
  • Store lithium-ion cells in the appropriate containers. Tip: use ADR-approved containers for storage of lithium-ion batteries.
  • Store the cells away from flammable and combustible materials.
  • Don’t store large quantities of batteries if not necessary.
  • Keep damaged and new cells separated.
  • Keep a fire extinguisher specifically designed for lithium-ion near the cells.
  • Collaborate with the fire department to create building compartments, install fire detection and suppression systems and analyse the risks in your storage space.

Are you in charge of transporting lithium-ion batteries? Discover the three things you have to get right for safe transport in this article.

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  • caseThe Waste Management Hierarchy: how to deal with end-of-life EV batteries?The EU proposes a 5-stage ‘Waste Management Hierarchy’, as a guide to deal with waste in the most environmentally desirable way. Discover what this means for your used EV batteries.Read more
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