Introduction
B.I.G. welcomes the opportunity to comment on this first of its kind National Guideline for Safe Management of End-of-Life Lithium-ion Batteries.
As a New Zealand industry organisation working to establish a regulated product stewardship pathway for large batteries, B.I.G. acknowledges both the intent and importance of the documentation and supporting consultation in working toward harmonising work relating to battery collection, transportation, and processing across the jurisdiction.
Large lithium-ion batteries, such as those used in electric vehicles, buses, trucks, and stationary energy storage systems, represent one of the fastest growing and highest value waste streams. They also present significant health, safety, and environmental risks if not managed appropriately. Clear guidelines are essential to enable safe handling and efficient resource recovery, and to support the development of a stewardship scheme.
Overall position
We support the draft guideline in principle and consider it a critical foundation for:
- Trans-Tasman alignment
- Safe and consistent handling of large-format batteries
- Development of a circular, high-value resource recovery system
- Establishment of a robust product stewardship scheme
The guideline will help New Zealand avoid a fragmented approach, and ensure that industry, regulators, and emergency services operate from a shared understanding of risk and best practice.
Why New Zealand should support improved resource recovery for large batteries
Critical materials security and economic opportunity
Large lithium-ion batteries contain significant quantities of lithium, nickel, cobalt, manganese, copper, and aluminium – all of which New Zealand imports.
Improved resource recovery:
- Reduces reliance on volatile global supply chains
- Supports regional circular economy development
- Creates opportunities for local processing, refurbishment, and second-life applications
A clear guideline provides certainty needed for investment in dismantling, repurposing, and recycling infrastructure.
Enabling a viable product stewardship pathway
A stewardship scheme for large batteries requires:
- Standardised collection and transport protocols
- Clear damage classification and packaging requirements
- Standardised collection points
- Safe pathways for second-life assessment and repurposing
The draft guideline provides the technical and safety foundation needed to design a stewardship scheme that is both practical which addresses some of the challenges associated with scheme design.
Without consistent guidance, industry faces uncertainty that inhibits investment and slows scheme development.
Alignment with New Zealand’s climate and circular economy goals
Supporting the guideline directly advances:
- The New Zealand Waste Strategy 2023
- The Emissions Reduction Plan
- Priority product stewardship advancement under The Waste Act 2008
High-value recovery of large batteries reduces lifecycle emissions, supports electrification, and improves New Zealand’s resource recovery efforts. Health and safety guidance also serves to allow growth in secondary life options for large batteries, including refurbishment.
Why New Zealand should support stronger health and safety controls
Reducing community and environmental harm
The consultation notes that lithium-ion batteries are implicated in around one fire per day across Australia and New Zealand. Large batteries carry far higher energy density, meaning:
- Greater thermal runaway risk
- More severe fire potential
- Higher consequences for workers, facilities, and communities
New Zealand’s waste and recycling facilities, often smaller and located in rural areas, are particularly vulnerable. A recent WasteMINZ report supports this with a scan of the New Zealand environment surrounding the small battery sector and the need for a mandatory product stewardship scheme as communities are bearing the costs and consequences of battery disposal.
This guideline builds on this by providing a consistent baseline for safe storage, handling, and transport of large batteries, which in turn protects emergency responders, communities, and facility operators.
Protecting workers across the supply chain
A stewardship system for large batteries will involve:
- Vehicle dismantlers
- Service centres
- Freight operators
- Second-life refurbishers
- Recyclers
B.I.G. supports the consideration of these key points to help reduce the risk of injury, facility fires, and environmental contamination.
Importance of Trans-Tasman harmonisation
New Zealand’s market for large batteries is currently small. A viable stewardship system is required before the number of batteries reaching end-of life becomes problematic. A successful product stewardship scheme depends on a number of factors:
- Shared standards with Australia
- Cross-border logistics and processing
- Economies of scale in recycling
- Consistent industry training and documentation
- Investment in onshore processing
- Confidence in network
Aligning both Australia and New Zealand’s approach to handling and processing large batteries, provides a common-sense approach to addressing a burgeoning problem.
Recommendations for strengthening the final guideline
We recommend the following enhancements to ensure the guideline fully supports a large battery product stewardship scheme that includes options for secondary life/refurbishment:
Clear damage classification framework
Industry requires:
- Visual and diagnostic criteria – would be useful and assist with training
- Guidance for safe transport of damaged units
Integration with second-life pathways
The guideline could move to support:
- Testing and grading for reuse
- Safe disassembly for module-level repurposing
Conclusion
Battery Industry Group (B.I.G.) strongly supports the development of the National Guideline for Safe Management of End-of-Life Lithium-ion Batteries. For large batteries in particular, the guideline provides the essential foundation for safe handling and transport, resource recovery, worker and community protection, and Trans-Tasman consistency.
These are all aspects that will assist us to advance the product stewardship conversation in New Zealand. We welcome continued engagement as the guideline is finalised and implemented.
About 3R Group
3R Group are Aotearoa New Zealand’s leading experts in designing and implementing both regulated and voluntary product stewardship schemes that drive real-world circular economy outcomes.
3R Group’s strength lies in bridging the gap between government and industry to co-create practical, scalable solutions that reduce environmental harm and waste across Aotearoa. With experience in navigating complex regulatory landscapes and engaging diverse stakeholders, we develop stewardship schemes that are compliant with legislation as well as commercially and environmentally sustainable.
We have been working with Battery Industry Group since phase two of the project to develop a regulated product stewardship for end-of-life large batteries.
About Battery Industry Group (B.I.G.)
B.I.G. is a group of stakeholders brought together to co-create a product stewardship scheme after large batteries were declared a priority product in June 2020 under the Waste Minimisation Act 2008. Our purpose is to ensure that batteries are a valuable resource in Aotearoa’s journey to a low emissions future.
B.I.G. operates under the governance of Auto Stewardship New Zealand, a not-for-profit product stewardship organisation. Auto Stewardship New Zealand, provides governance structures for all regulated, vehicle related product stewardship schemes, including Tyrewise and B.I.G.
B.I.G. is referenced in the guideline under 2.2.2 and has a focus on batteries that are over 5kg (not lead acid). B.I.G. has applied to Ministry for the Environment for product stewardship accreditation as a priority product.
B.I.G supports the inclusion in scope of large batteries from automotive batteries and battery energy storage systems due to obvious synergies in both chemistry and associated risk, regardless of size.
