The regulatory grey zone that long blocked second life
A battery removed from a scooter or an electric vehicle raises an unexpected legal question: what exactly is it? Waste to be processed? A used good to be resold as-is? Or a new product, once you turn it into a storage pack?
For a long time, the absence of a clear answer held back the whole reuse industry. Without a defined status, it was impossible to know who bears responsibility for safety, or which standards the final product must meet. That is the heart of the second-life “standards problem.”
What EU Regulation 2023/1542 changes
The European batteries regulation (EU) 2023/1542 removed the ambiguity. Its principle is blunt: an operator who prepares a battery for reuse, requalifies or remanufactures it, then places it on the market, is considered the manufacturer of that battery.
In other words, requalifying a battery and selling it is not “moving used stock”: it is placing a new product on the market, with everything that entails — conformity, safety, CE marking, technical documentation, new labelling (including the QR code signalling the change of status) and extended producer responsibility (EPR).
The consequence is clear: a second-life battery cannot be sold “as is.” It must meet the same market-access requirements as a new battery — and someone must take on that responsibility.
cirBATT, a manufacturer in the eyes of the law
That is exactly the status cirBATT takes on. When we requalify cells and assemble a pack, we are not reselling used goods: we place a new product on the market, of which we are the manufacturer. With all that implies: a technical file, conformity assessment, marking, labelling and end-of-life responsibility.
This status is not a burden we endure: it is the backbone of our model. Being the manufacturer means owning your tests — and being able to guarantee what you sell, with the measurements to back it.
The tests required to place a battery on the market
Placing a storage battery on the market means satisfying a set of tests, grouped into families and tied to reference standards:
| Test family | Examples | Reference |
|---|---|---|
| Performance & characterisation | Real capacity, internal resistance, SOH, cycle endurance | IEC 62620 / 61960, UL 1974 |
| Electrical safety (abuse) | Overcharge, forced discharge, external short-circuit, insulation / dielectric strength | EN IEC 62619 |
| Thermal safety | Thermal cycling, temperature performance, thermal abuse / propagation | EN IEC 62619 |
| Mechanical safety | Vibration, shock, drop | EN IEC 62619 / UN 38.3 |
| Transport (8 tests) | Altitude, thermal cycling, vibration, shock, external short-circuit, impact/crush, overcharge, forced discharge | UN 38.3 |
| Conformity & marking | CE (EMC, low voltage), labelling, QR, carbon footprint, due diligence | Regulation (EU) 2023/1542 |
It is a demanding specification — and that is a good thing: it separates a serious battery from an improvised assembly.
A workshop equipped to run these tests
Because we are the manufacturer, we bring the controls in-house. The cirBATT workshop is equipped to characterise and stress cells and packs against these requirements:
- Charge/discharge cyclers — real capacity, curves, cycle endurance;
- Internal-resistance measurement — to anticipate load behaviour and detect weak cells;
- Climatic / thermal chambers — thermal cycling and temperature performance;
- Insulation and dielectric-strength tester — the pack's electrical safety;
- External short-circuit rig and overcharge / forced-discharge tests;
- Mechanical tests (vibration, shock) and thermal imaging with data logging;
- BMS validation bench, developed in-house for our packs.
Every claim on our product sheets — capacity, SOH, safety — is thus backed by a measurement, cell by cell and pack by pack.
Why it matters for you
Whether you are an individual, an installer or an integrator, the point is simple: you are not buying a “used” pack of uncertain status, but a product whose manufacturer takes on conformity — marked, documented, guaranteed. The same standard as a new product, at second-life cost.
This is also what underpins our offer to professionals — tested cells and BMS — and what makes a second-life battery not only cheaper, but often safer than a brand-new one.
In short
The second-life “standards problem” was, first of all, a problem of responsibility. Regulation (EU) 2023/1542 settled it: whoever requalifies and places a battery on the market is the manufacturer. cirBATT fully takes on that role — and has, in its workshop, the means to run the tests that make the difference between a battery you merely inherit and a battery you truly control.