[i] Capacity Methodologies are inconsistent and unreliable (or not available)

1. “The major challenge in determining the health of a lithium-ion battery is that there is no single measurable quantity that is indicative of battery health. One of the most popular metrics used to report on battery health is the normalized discharge capacity of the battery, defined as the amount of charge that the battery is capable of delivering at any given time with respect to the amount of charge it could deliver at the beginning of its life. The problem with this metric is that it requires a full discharge in order to be measured, and it can be confounded by usage conditions subject to varying load levels. Additionally, using only the available charge to represent a battery’s health neglects the degradation in the battery’s power capabilities, which is especially important in high discharge rate applications. The other metric commonly used to represent battery health is the equivalent resistance. This metric is related to the observed voltage drop that occurs at a given discharge current. While this metric can be measured quickly (because does not require a complete discharge) it does not always increase monotonically with battery usage and often suffers from significant measurement noise.” - Center for Advanced Life Cycle Engineering, University of Maryland, September, 2014 Newsletter, page 10.

2. “Knowing the health of a battery is important, but no practical method exists that can quantify all conditions in a short, comprehensive test. State-of-health (SoH) cannot be measured per se, only estimated to various degrees of accuracies based on available symptoms.” http://batteryuniversity.com/learn/article/how_to_know_end_of_battery_life

[ii] The PACE battery testing guidelines are inconsistent in their treatment of acceptable battery capacity and give no real justification for the 80% capacity or 1 hour run time threshold

1. “1 hour is a minimum charge a battery should hold, although some users of laptops may request more useable runtime. It should be noted that some end users will also be able to make use of batteries with less capacity, for example a battery able to hold 40 minutes capacity need not be discarded, and can have use for those principally connecting the laptop to a reliable electricity supply using the charger, however, for the purposes of this guideline and for export, batteries must hold at least a one hour charge.” Footnote on page 40 of http://archive.basel.int/industry/compartnership/docdevpart/ppg11DraftGuidelineFinal-2011-03-15.pdf

2. “’Hold an appropriate charge’ means a battery, when used in a particular system, is capable of powering the system for a time period which meets the needs of a target user, and for at least 1 hour.” Footnote on Page 43 of http://archive.basel.int/industry/compartnership/docdevpart/ppg11DraftGuidelineFinal-2011-03-15.pdf. But what is a “target user?” That is a very subjective term recognizing that different secondary computing uses have different battery capacity needs, yet the PACE Guidelines conclude to use a single capacity requirement – this is incongruous reasoning.

3. Batteries are rarely relied on as a power source for laptop users. It has been reported that the battery supplies the power to a laptop less than 2% of the time a laptop is in use (otherwise, it’s plugged into the grid).

[iii] The process of disallowing working batteries to be reused is contrary to the Waste Management Hierarchy

1. “In many cases, however, users discard fully functional laptop batteries prematurely, when many could be retained in use or for re-use.” Page 43 of PACE Guidelines http://archive.basel.int/industry/compartnership/docdevpart/ppg11DraftGuidelineFinal-2011-03-15.pdf

2. “Battery recycling is energy-intensive and it takes 6–10 times more energy to reclaim metals from recycled batteries than through other sources, including mining.” http://batteryuniversity.com/learn/article/battery_recycling_as_a_business

3. “The key in reducing the battery wasteland, however, is to respect batteries by treating them well and only discard them when no salvage remedy exists. Better charge methods, clever battery monitoring systems (BMS) and advanced battery test devices help in getting the full life out of a battery. Too many batteries are being replaced as a way to troubleshoot an apparent problem.“ http://batteryuniversity.com/learn/article/battery_recycling_as_a_business

[iv] The restrictions proposed do nothing to address the challenge of recycling end of life rechargeable batteries in Developing countries

Stopping the flow of lower capacity batteries to developing countries does not mean that these counties will then have no issues with rechargeable battery disposal and recycling. Their domestically generated e-waste produces plenty of spent rechargeable batteries on its own. Also, replacing high quality OEM batteries from refurbished laptops that are generally safer and more durable than aftermarket batteries as a means to extend the life of a laptop may do more harm than good. In addition, there are rechargeable primary lithium, Ni-Cd and other batteries installed on laptop and desktop motherboards which require a sustainable end of life management solution as well.

To protect the environment in developing countries from improperly disposed batteries, we need to encourage and help them develop sustainable, safe and effective battery recycling programs within their regions. Sure, let’s not send near end of life batteries abroad – but forcing people to scrap/recycle batteries with many years of productive life ahead of them creates more environmental pollution for the entire world and does nothing to solve the problem of proper end of life management of spent batteries in developing countries.