The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) officially rates lithium batteries that need to be disposed into three categories, regarding their condition: “End of Life”, “faulty/critical” and “not safe for transport”.
Like the name indicates, it’s about lithium-ion batteries that need to be disposed due to their age. For example, these batteries won’t reach the expected charge capacity. But also new goods can be considered end-of-life goods – depending on their condition – for example due to quality reasons from the manufacturer.
Faulty and therefore critical batteries and cells are those that:
Batteries and cells not safe for transport
This is about batteries and cells that show signs of impending damage. These sings can be as follows:
The battery act obliges users of device batteries to return and leave them at installed return systems like GRS, ERP or manufacturer-owned return systems.
Further, manufacturers are obliged to take care of collection and provide for fitting packaging at the collection points. Manufacturer-owned or registered return systems (GRS, CCR Rebat, ERP, ÖcoReCell) can be commissioned to do that.
In practise, fact is that anyone that puts batteries into circulation is also obliged to dispose them. Further, all distributors of batteries in Germany are listed in the BattG register.
For more information on the German battery act (BattG) click this link: http://www.gesetze-im-internet.de/battg/index.html
Like in many other fields, there are special provisions for batteries and certain substances. One of those is the special provision 636.
P909 PACKING INSTRUCTION P909
This instruction applies to UN Nos. 3090, 3091, 3480 and 3481 carried for disposal or recycling, either packed together with or packed without non-lithium batteries.
(1) Cells and batteries shall be packed in accordance with the following:
(a) The following packagings are authorized, provided that the general provisions of 4.1.1 and 4.1.3, are
Drums (1A2, 1B2, 1N2, 1H2, 1D, 1G);
Boxes (4A, 4B, 4N, 4C1, 4C2, 4D, 4F, 4G, 4H2);
and Jerricans (3A2, 3B2, 3H2).
(b) Packagings shall conform to the packing group II performance level.
(c) Metal packagings shall be fitted with a non-conductive lining material (e.g. plastics) of adequate strength for the intended use.
(2) However, lithium ion cells with a Watt-hour rating of not more than 20 Wh, lithium ion batteries with a Watthour rating of not more than 100 Wh, lithium metal cells with a lithium content of not more than 1 g and lithium metal batteries with an aggregate lithium content of not more than 2 g may be packed in accordance with the following:
(a) In strong outer packaging up to 30 kg gross mass meeting the general provisions of 4.1.1, except 126.96.36.199, and 4.1.3.
(b) Metal packagings shall be fitted with a non-conductive lining material (e.g. plastics) of adequate strength for the intended use.
(3) For cells or batteries contained in equipment, strong outer packagings constructed of suitable material, and of adequate strength and design in relation to the packaging capacity and its intended use, may be used. Packagings need not meet the requirements of 188.8.131.52. Equipment may also be offered for carriage unpackaged or on pallets when the cells or batteries are afforded equivalent protection by the equipment in which they are contained.
(4) In addition, for cells or batteries with a gross mass of 12 kg or more employing a strong, impact resistant outer casing, strong outer packagings constructed of suitable material and of adequate strength and design in relation to the packaging’s capacity and its intended use, may be used. Packagings need not meet the requirements of 184.108.40.206. Additional requirements:
1. Cells and batteries shall be designed or packed to prevent short circuits and the dangerous evolution of heat.
2. Protection against short circuits and the dangerous evolution of heat includes, but is not limited to:
3. Cells and batteries shall be secured within the outer packaging to prevent excessive movement during carriage (e.g. by using a non- combustible and non-conductive cushioning material or through the use of a tightly closed plastics bag).
No. The RETRON system works without using any inert bulk materials.
Due to the increasing demand of possibilities of disposal of batteries keeping sustainability and the desire for easy handling in mind, we developed a packaging system in the year 2017 which has been approved by the Federal Institution for Material Research and Testing ( Bundesanstalt für Materialforschung- und Prüfung, BAM) for usage in Europe.
In interaction the RETRON inner and outer packaging form a system that allows for storage and transport of faulty lithium batteries. Both containers and bags offer extraordinary qualities for reducing the risk when storing end-of-life batteries or new goods on their own. Important: Due to permission policies RETRON packaging systems currently can only be used for the transport of faulty batteries up to a unit weight of 30 kg and a total weight of 200 kg per container.
End-of-life batteries should possibly also be transported using RETRON containers according to packaging instruction P909.
Inner packaging (for faulty/critical batteries)
The RETRON inner packaging consists of a solid and fire-proof fabric material that is produced in the form of bags in different sizes for the respective batterie types. When exposed to heat through burning batteries one of the textile layers reacts and expands from approx. 2mm up to approx. 50mm. By enclosing the battery inside of the bag the oxygen supply to the fire is stopped. The approx. 50mm insulation layer prevents propagation to bags, batteries or other items close by. The fire-proof material and a special closure prevent flames from emerging from the inside to the outside.
Preventing the spread of a battery fire is the main task of the RETRON inner packaging. We have defined the following goals in advance and reached them by using a specially produced fire-proof material:
The bags can be produced in different sizes according to demand.
When creating the RETRON external packaging, we stuck to the ASP-container – a container well known and approved within the field of transport of hazardous material. The RETRON container family is available in the sized 240L, 460L and 600L. The additionally built-in insulation of this double-walled special container insulates a possible fire source (1.000°C) inside of the container for three days down to max. 100°C on the outside.
Specially embedded pressure valves allow for controlled leakage of gas that occur from an explosion or a combustion of lithium batteries in order to stop the oxygen supply back into the container.
A screw thread in standard measure allows to connect the ASP to existing gas removal systems or install an additional modular electrostatic precipitator. For transport, the remaining space needs to be filled with a mineral wool pillow (RETRON pillow).
Yes. REMONDIS provides a sustainability certificate for you.
Yes. Among others, the RETRON System is developed and approved for storage and transport of end-of-life batteries.
Yes. The RETRON container family is also ideal for storing new goods, faulty/critical batteries as well as for temporary storage during several work steps.
No. As our client, you can profit from the RETRON System nationwide.
Yes. Specially embedded pressure valves allow for controlled leakage of gas that occur from an explosion or a combustion of lithium batteries in order to stop the oxygen supply back into the container.
A screw thread in standard measure allows to connect the ASP to existing gas removal systems or install an additional modular electrostatic precipitator.
REMONDIS will transport the batteries to authorised treatment plants where they will be utilised materially in hydrometallurgical pyrometallurgical processes to ensure the return of valuable metals and components back into the cycle.
Unfortunately not. RETRON containers must be transported by a REMONDIS-owned logistic only.
Yes, it is. Our inner packaging comes in three standard sizes. However, it can easily be adjusted to cells, modules or battery packs.
Yes. As long as there are no signs of damage, the inner packaging is reusable.
Our inner packaging as well as our containers have been developed for the safe storage of batteries. The inner packaging has been developed to prevent ignition of the surroundings – when handled professionally, locked correctly and when placed in a fire-proof storage location. Further, the inner packaging allows for easy and safe charging of modern batteries, that don’t depend on a docking station.