A Turning Point for Battery Recycling in NSW
Sphere recently attended the Battery Recycling and Manufacturing Summit hosted by the Association for the Battery Recycling Industry . The event brought together leaders across the battery value chain to discuss emerging challenges, trends and opportunities, including the recent assent of the Product Lifecycle Responsibility Act 2025 by the NSW Government.
The Act marks Australia’s first mandatory product stewardship scheme, in which batteries or products containing embedded batteries are designated a regulated product due to rising safety concerns and escalating battery waste volumes. In NSW alone, over the last year 384 lithium battery incidents were reported, involving several deaths and at least 33 injuries.
The mandates introduced by the Act include:
Suppliers of regulated products (like batteries) must join or establish a product stewardship organisation approved by the EPA.
Suppliers must meet specific government-set targets related to product recovery, reuse, recycling, or disposal, as outlined in the regulations.
Brand owners and stewardship organisations are required to prepare and submit action plans that show how they will meet their stewardship obligations.
Participants must submit periodic reports (e.g. quarterly or annually) to the EPA and retain detailed records for at least six years for audit purposes.
The Act empowers the EPA to issue penalties, require corrective action, and enforce compliance through audits, investigations, and, if necessary, legal proceedings.
By requiring suppliers to join or establish stewardship organisations, the Act promotes changes to battery management through increased product lifecycle responsibility across the supply chain. Manufacturers and producers must now give greater consideration to the end-of-life recovery of the products they introduce to market.
This shift not only incentivises new investment in collection and recycling infrastructure but also strengthens the use of existing systems. In doing so, it drives innovation, supports the development of a circular battery economy, and helps reduce fire risks and environmental harm.
The legislation also lays a foundation for contributing to broader circular economy outcomes and resource recovery and recycling targets. By incentivising improved battery design and recycling-friendly formats, it creates opportunities for reuse, recovery, and domestic processing.
However, the Act is not without limitations.
The battery industry is evolving at a rapid pace. Speakers at the Summit reinforced this perspective, highlighting the rapid transformation and pace of innovation within the industry. Chemistries, form factors and applications are changing quickly. From next generation lithium iron phosphate (LFP) cells to solid-state batteries and energy storage systems, today’s stewardship may not fully account for tomorrow’s challenges, particularly the rapid pace of technology development and manufacturing overseas.
Furthermore, whilst NSW is leading the charge, Australia’s recycling landscape remains fragmented. Without a national framework and homogenous schemes, there is a risk of regulatory inconsistency, where producers face a patchwork of rules and varying enforcement across states. These discrepancies can discourage compliance, complicate logistics and lead to an uneven playing field, diluting the overall impact of well-intentioned policies.
Challenges for smaller businesses
The transition from voluntary to mandatory stewardship will also test the readiness of supply chains. Smaller importers or retailers may lack the resources to quickly align with new obligations, and monitoring compliance across a broad, evolving product base, from AA rechargeables to EV battery packs, will require robust oversight mechanisms and reporting systems.
Still, and more broadly, the Product Lifecycle Responsibility Act 2025 represents a bold and necessary first step towards improving the sustainable management of regulated products. It acknowledges that the true cost of production extends well beyond the point of sale, and that safety, resource recovery, and environmental protection must be treated as collective, long-term responsibilities.
The challenge now is ensuring that this momentum doesn’t stop at the NSW border or with only batteries. For Australia to build a truly circular economy, and keep pace with technological innovation, national alignment, adaptable regulation and industry-wide commitment is required.
