The European Commission Confirms: the Use of Electric Vehicle Batteries as Replacement Parts for Repairs is Permitted
The Finnish Auto Dismantlers Association, the Finnish Association of Scrap Dealers, and the Association of Automotive Service Providers view the European Commission’s response as an important victory for the circular economy and for extending the life cycle of usable automotive batteries. What is needed now are common rules for safe and traceable reuse.
On October 27, the European Commission responded to a written question from Member of the European Parliament Anna-Maja Henriksson regarding the repair and reuse of automotive batteries. The Finnish Auto Dismantlers’ Association, the Finnish Scrap Dealers’ Association, and the Automotive Service Providers Association (AAPT) addressed the response in a joint press release published on October 30.
The Commission clarifies
According to the Commission, scrapping a vehicle does not automatically turn the vehicle battery into waste. A used vehicle battery can be removed for repair, reuse, or remanufacturing before the vehicle is sent for scrap processing. If an end-of-life vehicle arrives at an authorized treatment facility with the battery still installed, the Commission considers the battery to be waste.
Its continued use requires, for example, preparation for reuse. Direct reuse and the preparation of a waste battery for reuse are different procedures. This distinction affects producer responsibility obligations.
The absence of repair instructions is not, in itself, decisive
According to the Commission’s response, the process constitutes remanufacturing only if all the conditions of the Battery Regulation’s definition are met. The organizations view this as supporting the interpretation that the absence of the manufacturer’s repair instructions alone does not transform a standard repair into remanufacturing.
The national processing model is open
The organizations propose exploring a two-stage end-of-life model in which the assessment of a battery’s continued use and the vehicle’s end-of-life disposal would be aligned with the Commission’s interpretation. Batteries would primarily be directed to official collection points as part of a documented treatment chain. The goal is to maintain the traceability of batteries and information on the stages of their life cycle.
The model has not yet been adopted. According to the organizations, the national guidelines must be revised, and procedures for direct reuse, repair, and the treatment of waste batteries must be clearly distinguished.
No timeline has been announced for revising the guidelines
AAPT has previously presented the views of workshops to the Finnish Parliament. The organization is seeking equal opportunities for battery repairs for operators who meet the requirements, as reported by AUTOMEDIAT in its September issue.
