The AADA welcomes the opportunity to make a submission in response to the exposure draft of the HEPA National Guidelines for the safe management of end-of-life lithium-ion batteries. In its submission, the AADA notes that EV batteries differ significantly from other lithium-ion batteries in their design, size, use, and the complexity of their integration into electric vehicles. It therefore recommends the development of a separate, comprehensive guide specific to EV battery recycling.
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