Understanding ReMA’s Guidance on Propulsion Battery End-of-Life Management

On Monday, December 8, 2025, ReMA's Board of Directors adopted the Position and Guidance on Propulsion Battery End-of-Life Management.

The rapid adoption of hybrid and electric vehicles (EVs) presents both significant opportunities and challenges. How do you safely and sustainably manage the growing volume of large-format batteries that power these vehicles once they reach end-of-life while preserving the ability and marketplace for recycling the vehicles themselves?

Propulsion batteries, including those that power electric and hybrid vehicles, are rich in critical minerals essential to both national security and the emerging clean energy economy. When managed responsibly, end-of-life propulsion batteries represent a vital source of recoverable resources that can be remanufactured, repurposed, and recycled. However, if handled improperly, these batteries have the potential to not only pose health and safety risks to those who manage them along the value chain but also create a loss of those vital materials.

To ensure the responsible end-of-life management of these batteries, ReMA supports a policy framework that prioritizes safety, clarifies responsibility, enables market-driven engagement, incentivizes critical minerals recovery, and strengthens U.S. capacity for battery reuse, repair, remanufacturing, repurposing, and recycling.

"If batteries have an end market that's viable then there's no issue, but if the batteries are coming down the line and they don't have an end market the states essentially want to make sure that the owners aren't left having to foot the bill," said Justin Short, ReMA's Assistant Vice President of State Affairs. "From conversations with manufacturers, dismantlers, and our members, ReMA's battery policy workgroup proposed the limited management program outlined in our position."

In its position, ReMA urges policymakers to reinforce-not replace-existing, effective systems by establishing clear, market-supportive policies. A successful framework should encourage collaboration, support business-to-business practices, and promote safe, economically sustainable recovery of critical minerals.

"Typically, the producer is the responsible party, but if another party has modified the battery in some way, like if it's been remanufactured by a third party that isn't contracted with the producer, then whoever did the modification would become the responsible party," Short said. "Our members who are involved in vehicle recycling are usually seen as secondary handlers where they are pulling the battery out to prepare it for transport and send it on to the end-of-life option. They aren't modifying the battery itself."

ReMA believes legislation should start by recognizing and supporting the existing marketplace for large format propulsion batteries. Policies must not undermine these well-functioning markets that already actively manage propulsion batteries through reuse, repair, remanufacturing, repurposing, and recycling, but instead provide clear direction and guardrails to ensure responsible outcomes in circumstances where the market does not function effectively.

Strategic and well-informed policy efforts, particularly those with a strong business-to-business (B2B) model, can provide the structure and clarity needed to support end-of-life management while avoiding disruption to existing recycling markets.