
Dr Steve Sloop of OnTo Technology outlines how the risk and cost of transporting end-of-life lithium-ion batteries can be addressed by neutralisation.
About half the cost of recycling lithium-ion batteries goes on moving them. They are critical for electric vehicles (EVs), which use large batteries. This has escalated the demand for cobalt, lithium and other critical materials.
The distribution of end-of-life lithium-ion batteries and concentrating them for recycling is a growing activity. According to Global Market Insights, the recycling market has a CAGR of 20.6%. End-of-life lithium-ion batteries have hazardous characteristics which US federal regulation CFR 49 requires regulatory conformation for public transportation.
Lithium-ion batteries, as common manufactured goods, are regulated under the Universal Waste rules. These outline best practices, which include isolating the electrical terminals to avoid short circuit, limiting the weight of material in a container, and having the batteries at 30% of full state-of-charge.
Shipper requirements
Also, the shipper must meet UN and or USDOT requirements for moving hazardous materials. Certifications, specialised training, refresher courses, shipping materials, weight limitations and reporting all contribute to the cost of moving end-of-life lithium-ion batteries. Even with all the best efforts, battery fires occur during shipping and storage.
One way to of ship end-of-life lithium-ion batteries is to keep them within the appliance – like they were shipped at the beginning of life under UN and or USDOT rules. Shipping bare lithium-ion batteries is dangerous due to the potential for short circuit and fire. Having them in the (new or old) device improves safety.
At end of life, the cells have protection of the physical covering, circuitry, and control features that may be present on a consumer electronic device. However, they are of limited value and require cost inputs at the destination. Shipping end-of-life lithium-ion batteries in the device concentrates them at a destination where they become a hazardous universal waste.
From examining many end-of-life batteries, I can attest that challenges for shipping end-of-life devices include:
- normal faded cells that are benign may be mixed with devices with damaged lithium-ion batteries
- state-of-charge may be difficult to verify
- the state-of-health cannot be reliably confirmed.
The practically unverifiable states for end-of-life lithium-ion batteries surround them with uncertainty and risk.
Regulatory response
Extended Producer Responsibility (EPR) has been the regulatory response to the problems of electronic waste in general. EPR only identifies the problem and directs the responsibility to the producer. However, the producer may not have the equipment and infrastructure to address the problem any better than a municipal waste collector or electronics or EV battery recycler, that may receive an end-of-life lithium-ion battery within or outside of a device.
The UN 3480 classification directs proper packaging for end-of-life lithium-ion batteries and proper training for personnel to package them, as well as proper training and limitations on the shipping of end-of-life lithium-ion batteries.
All of this translates to the cost for logistics of end-of-life lithium-ion batteries. EPR aims to reduce environmental impact by shifting the burden of waste management from individuals and governments to the companies that create the waste.
An EPR system to capture end-of-life lithium-ion batteries has one major reality: the value of the scrap itself based upon the inherent materials is not enough to motivate collection and reverse distribution.
The value of an old one pound may be $2.50 (depending on LME prices) worth of cobalt after smelting and purification. Experience shows that improving the value of end-of-life lithium-ion batteries is achieved through concentrating the items.
The concentration of end-of-life lithium-ion batteries increases the inherent potential value and the inherent risk and liability. To engineer the supply chain of materials, from recycling to manufacturing, accumulation of end-of-life lithium-ion batteries occurs to meet feedstock for a recycling plant. To engineer for accumulation of potential value in a realistic method, the risk of fire in end-of-life lithium-ion batteries needs to be eliminated prior to accumulation.
One end-of-life battery in a waste stream can cause a fire. However, if it is neutralised, it will not catch fire. Accumulating neutralised batteries is, therefore, not risky.
Neutralising the battery

The first opportunity for battery neutralisation is the collection point or hand-off for the customer, consumer or owner of the end-of-life lithium-ion battery device. This assumes the owner does not resell the device and ship it to another location – in which case it is not really end of life.
In the US, the location where the hand-off occurs will increasingly be to a waste hauler with a dedicated e-scrap service day, a retail store, community hazardous waste generation site, or industrial recycler such as Waste Management, Republic or numerous US county-based e-scrap collection services.
Accumulation point
The initial accumulation point is where OnTo Technology envisages implementation of battery neutralisation. It is performed in batches using patented, verified processing developed by OnTo. Without neutralisation, end-of-life lithium-ion batteries would be packaged in their devices and shipped to a secondary accumulation location.
The thesis for OnTo’s battery neutralisation process is to be less expensive than packaging and shipping of universal waste in 60lb batches. For island locations, that cost can be as high as $1,200; and the risk to the carrier could be insurance including maritime transport. For any location, the risk remains constant unless there is elimination of the inherent hazards.
Insurance
Insurance is becoming a major concern in the logistics for end-of-life lithium-ion batteries. For the island example, shipping end-of-life lithium-ion batteries is limited to ground transportation. Maritime shipping assumes the risk for transportation from an island to the mainland, or from anywhere to an Asian destination for recycling.
Maritime shipment of EVs was marred by the fire and total loss of the 60,000gt car carrier, Felicity Ace, bound from Europe to the US in 2022. It caught fire and burned for more than a week before recovery teams could board. The ship, which was en route from Emden, Germany, to the US, sank while being towed and is now two miles beneath the surface of the Atlantic Ocean.
The crew safely abandoned ship but the vessel’s cargo, almost 4,000 vehicles including Porsches, Audis and Bentleys worth an estimated $330 million, was lost. Anticipated wreck salvage costs mean total damages were initially expected to hit around $500 million.
The risk profile for end-of-life batteries will be worse as they have been shown by Argonne National Lab to contain flammable gas build-up. Other known conditions from lithium-ion battery failure mechanisms include dendritic lithium, unbalanced cells, reversed polarity cells, and God knows what else.
For maritime shipment of batteries, the insurance liability includes the repair of damage to the vessels, cargo, people and environment. There is a major discrepancy between the value of a vessel and the value of the battery (new or old). The obvious outcome is costly shipping for batteries.
Manufacturers such as PEC are responding to the transportation challenge by shipping dry cells that have no hazardous characteristics. Batteries are then assembled and activated at the destination.
Similarly, deactivating and neutralising batteries prior to shipment eliminates the hazardous risks and costs for transportation at end of life.

Neutralisation is practised and demonstrated by OnTo through a development project with the United States Defense Logistics Agency. In October 2024 the battery neutralisation technologies were demonstrated on location at military installations in Hawaii: Marine Corps Base Hawaii and Army Garrison Hawaii – Schofield Barracks. Common military-format lithium-ion batteries were neutralised by ProteQ Inc., using OnTo Technology’s patented processing.
The demonstration processed two individual packs. The packs were prepared via discharge and mechanical piercing before being exposed to pressurised carbon dioxide in an autoclave. The two-part preparation assures success of the process of neutralisation. It allowed for the treatment to eliminate flammable metals and solvents and yield an inert item.
Third party testing, via Sandia National Laboratories, verified non-flammability of the cells. The cost of the process is $5–15 per batch (OpEx and CapEx). The result is elimination of costs for class-9 packaging and shipping, which is approximately $20. The potentially greater benefit is the risk of storing and insuring hazardous material is also eliminated.
Game changer
The due diligence on the demonstration yielded three game-changing facts for the end-of-life lithium-ion battery industry:
- the process of neutralisation is not a treatment in the regulatory sense of the word. The process is not thermal and does not require a stack for dispersing burn-off gases
- the processor is not a fired pressure vessel
- the neutralised product has received a letter of interpretation from the US Department of Transportation Pipeline Hazardous Materials and Safety Administration (PHMSA). It states that material that goes through the process is no longer considered batteries. They do not have hazardous characteristics of flammability and toxicity.

The demonstration showed battery neutralisation can be practised in a relevant environment of a hazardous waste generation site on a military base. The batch volume for the prototype projects the scale of 100lb/day, which can address the demands from the facility.
The low system cost and modular scale allow for high throughput, and the small footprint allows for the dispersed utilisation of neutralisation at or near the source of end-of-life lithium-ion batteries. Reaching tons per day of throughput is envisaged through dispersed use of battery neutralisation at numerous sites in a region – reducing the logistics risk.
Battery neutralisation, with widespread practice close to the initial accumulation points, can provide relief to cost and risk in establishing the reverse logistics necessary for the economic recycling of critical materials from used batteries for manufacturing new ones.