The Spent Battery Industry, a Shift from “Waste” to a “Critical Resource”

On March 30, 2026, the Legislation and Judiciary Committee of the National Assembly passed, with amendments, the “Bill on the Management of Spent Batteries and the Promotion of the Related Industry” (hereinafter the “Spent Battery Act”), and its passage through the plenary session is expected going forward.

This bill is projected to function as a framework act that redefines spent batteries as industrial resources and comprehensively regulates the full life-cycle management system, including distribution, reuse, remanufacturing, and recycling.

It carries particular significance as legislation intended to secure supply-chain stability and industrial competitiveness in response to the expansion of electric vehicles and ESS, as well as the strengthening of global regulations such as the EU Battery Regulation.

The following examines the key provisions of the Spent Battery Act.

Legal Reclassification as an Industrial Resource and Scope of Application

Spent batteries are regulated as industrial resources rather than as waste, and the scope of application is as follows.

• Batteries in electric, hybrid, and hydrogen vehicles
• Batteries installed in construction and agricultural machinery
• Other energy storage system batteries

In addition, where no special provision exists in another statute, this Act applies with priority.

Establishment of a Policy Committee and an Integrated Management System

A “Spent Battery Policy Committee” under the Ministry of Economy and Finance is to be established, and it will oversee policy coordination, transactions and registration, safety management, the history-tracking system, and the enactment and amendment of statutes.

This committee will serve as a control tower that integrates and coordinates industrial, environmental, and safety policy.

Regulatory System by Type of Business Operator

① Distribution Operators

• Imposition of a registration obligation
• Transactions permitted only between registered operators
• Criminal punishment in the event of a violation

② Reuse Operators

• Registration obligation
• Mandatory enrollment in a mutual-aid program or insurance, strengthening consumer-protection responsibility

③ Remanufacturing Operators

• Registration under the “Motor Vehicle Management Act” serves in lieu thereof
• However, separate compliance obligations and an obligation to provide performance-evaluation information exist

④ Recycling Operators

• Permission under the “Wastes Control Act” serves in lieu thereof
• Separate compliance requirements apply

This represents a structure in which double regulation is partially eased for each type of operator, while substantive management and responsibility are strengthened.

Performance-Evaluation and Safety-Inspection Obligations

• Obligation to conduct a performance evaluation before separating the battery
• Obligation to conduct a safety inspection before distribution
• Periodic safety inspection at three-year intervals

In particular, sanctions have been introduced, including criminal punishment for the forgery or alteration of a performance evaluation and the imposition of an administrative fine where a performance evaluation is not conducted.

Recycled-Material Certification and a Content-Ratio Target System

• Certification of recycled-material production (Ministry of Environment)
• Certification of the content ratio (Ministry of Trade, Industry and Energy)
• A recycled-material content-ratio target may be set

The content-ratio target system is scheduled to take effect separately within two years after the enforcement of the Act, and it is a key regulation directly linked to compliance with the EU Battery Regulation and to supply-chain strategy.

Industrial Promotion and Support Policy

• Establishment of a public transaction system
• Operation of a history-tracking system
• Recommendation of preferential purchasing of remanufactured and reused products
• Tax support may be provided
• Support for technology development and workforce training

Because the Spent Battery Act is a “regulation-centered legal framework” that imposes clear obligations and responsibilities on each type of business operator, each company needs to proactively review the risks suited to its own business structure.

In particular, because the Act is designed as a structure that combines registration, certification, safety management, and supply-chain response, building a company-wide compliance system, rather than addressing a single area, is indispensable.

Distribution Operators: Registration Obligation and Criminal-Punishment Risk

After the enforcement of this Act, distribution operators are required to register with the Minister of Trade, Industry and Energy, and the structure shifts to one in which transactions are permitted only between registered operators.

Accordingly, conducting distribution, brokerage, or arrangement activities while unregistered, or transacting with an unregistered operator, may make a party subject to criminal punishment.

In addition, because the registration requirements (such as facility and personnel standards) are delegated to subordinate legislation, there is also a possibility that, depending on the content of the enacted enforcement decree, an existing business structure itself may become impossible to maintain.

Points for Response

• Reviewing in advance whether the business is subject to registration and the applicable requirements
• Building a system to verify whether counterparties are registered
• Redesigning the business structure in line with developments in subordinate legislation

Reuse Operators: Consumer-Protection Responsibility and Insurance Risk

In addition to the registration obligation, reuse operators are subject to an obligation to enroll in a mutual-aid program or insurance, which is a structure under which the operator bears responsibility directly when consumer harm occurs.

Because spent batteries show large performance variation by product and carry a high likelihood of safety problems, an accident may expand into civil liability for damages and product-liability (PL) risk.

In particular, the insurance-enrollment requirements and the scope of coverage may have a direct effect on the sustainability of the business.

Points for Response

• Reviewing in advance the structure and coverage scope of mutual-aid and insurance products
• Building a quality-management system based on performance-evaluation results
• Preparing a process for responding to consumer disputes

Remanufacturing Operators: Dual-Regulation and Compliance-Obligation Risk

For remanufacturing operators, registration under the “Motor Vehicle Management Act” is deemed to constitute registration under the Spent Battery Act, but this can be regarded not as regulatory relief but as the beginning of a dual-regulation structure.

That is, because compliance requirements under the Spent Battery Act and the obligation to provide performance-evaluation information, among others, apply separately in addition to the existing obligations under the Motor Vehicle Management Act, conflicts between statutes or overlapping regulation may arise.

Points for Response

• Analyzing whether regulation overlaps with the Motor Vehicle Management Act
• Building a system for performance evaluation and data provision
• Conducting integrated monitoring of developments in the amendment of related statutes

Recycling Operators: Combined Environmental and Industrial Regulatory Risk

For recycling operators, permission under the “Wastes Control Act” is recognized, but separate compliance requirements under the Spent Battery Act apply in addition.

This is a form in which industrial-policy regulation is combined with the existing structure centered on environmental regulation, and the intensity of regulation may increase going forward.

In particular, this is a structure in which an administrative disposition, criminal liability, and liability for damages may all arise at the same time when environmental pollution or a safety accident occurs during the battery-recycling process.

Points for Response

• Checking regulatory consistency with the Wastes Control Act
• Strengthening environmental and safety management standards
• Building a response manual for when an accident occurs