Case Estonia | Repurposing of EV-batteries: Insights from Estonian Stakeholders
Authors: Noman Shabbir, PhD, Research Fellow and Jelizaveta Krenjova-Cepilova, PhD, Researcher & Project Manager, FinEst Centre for Smart Cities
In Estonia, interest in second-life battery applications is emerging alongside broader discussions on energy security, renewable integration, and circular economy strategies. The TREASoURcE project studies the possibilities for the use of second-life battery packs for energy storage in other applications to avoid recycling the batteries back to the original elements with significant material losses in the process.
The global transition toward electrified transportation is accelerating rapidly, driven by climate targets, technological advances, and supportive policies. As electric vehicle (EV) adoption increases so too does the volume of retired EV batteries. While these batteries often retain 70–80% of their original capacity at end-of-life (EoL) in an EV, their disposal presents environmental and economic challenges.
At the same time, the growing demand for stationary energy storage—crucial for integrating variable renewable energy sources—presents an opportunity to repurpose second-life EV batteries for stationary applications. This dual challenge and opportunity have spurred international interest in the circular economy potential of battery repurposing and reuse.’
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Broad Support but Fragmented Readiness
Both private and public stakeholders in Estonia express support for enabling second-life battery applications, recognizing their potential contributions to energy security and sustainability. However, the ecosystem is not yet technically or institutionally prepared to implement these solutions at scale. On a social dimension, as the share of battery-powered devices in daily lives in Estonia is growing rapidly, it is important that people’s awareness of using battery devices safely increases alongside this development.
As batteries are technologically complex, their use requires the user to know how to charge, store, and maintain them correctly. According to the Rescue Board, 93 building fires caused by batteries and 18 fire hazards were recorded in Estonia in the last three years. In the first two months of 2025, an additional 6 fires and 1 fire hazard have been registered. An average of 30-40 cases are recorded each year. The larger fires are related to vehicle batteries, power banks, and solar panel storage batteries[1] (Postimees 2025).
As the stakeholders suggest, nationwide awareness campaigns on the safety of the use of batteries are essential. In the words of one of the interviewees, “Electricity today is conditionally number 1 in causing fires, and the reason is not the device released by the manufacturer, but the installation and usage” (Workshop 2025).
[1] Lithium-ion batteries pose a significant fire hazard, primarily due to the possibility of a ‘thermal runaway’ – a dangerous electrochemical reaction that occurs when there is a short circuit between the anode and cathode (The Fire Protection Association 2025).
Regulatory and Role Ambiguity in Installation
The Estonian context suffers from unclear responsibilities regarding the classification, regulation, and supervision of second-life batteries. Workshop discussions revealed a lack of consensus on which institution(s) should oversee the safety, installation, and approval processes of repurposed batteries. According to the Battery Regulation, when the EV battery is used for another purpose, the administrative procedure of changing the intended use of the product should be started.
This implies that the battery goes back to the market and the battery installer releases it under its own name as well as takes responsibility for this product. The issue has been discussed with the stakeholders who agree on the importance of a responsible installer/repurposing operator. As one interviewee emphasized: “Any type of installer for this second-life battery must give you a guarantee and they must give a technical data sheet, (…) technical energy audit or (…) a safety signature basically (…) and I would put all responsibility on the installer here” (Interview B 2024).
The installer or repurposer is also considered to be legally the battery manufacturer. In Estonia, however, the challenge is the absence of an accredited conformity assessment body, that would need to assess if the repurposed battery is safe to handle and if it conforms to all regulations.
Additionally, inconsistent or unclear classification systems (waste vs. product) further complicate ownership, traceability, and producer responsibility obligations. As the stakeholders noted, the approach of repurposing might play a role in defining the battery either as waste or as the product/equipment: if the modular approach is used, then some parts of the battery might be considered as waste, but if the battery is used as a whole, it can be considered a product. Nevertheless, as outlined by the interviewee, this issue still remains a “gray area” as it requires clarity and consensus among different stakeholders.
Also, the importance of knowledge of repurposing practices in general is well illustrated by one of our interviewees: “It’s really important (…) to understand the depth of repurposing. So, if it is disassembling the entire EV battery pack, picking out the cells and creating a new product based on the cells is one thing. Another thing is totally just unscrewing it from the bottom of the car and putting (…) inside your house, which also has been done in Estonia in these cases as well. And with the second case, I do personally have some concerns for the people who have done that” (Interview A 2024).
Education and Training
As the previous section demonstrated, the importance of correct installation as well as certified and competent repurposing operators cannot be underestimated. Our stakeholders discussed that there is a need for capacity building in terms of training programs to upskill local engineers and technicians in battery diagnostics, safety assessments and repurposing techniques. This implies close cooperation between applied higher education institutions, universities as well as battery manufacturers.
Safety and Responsibility as Central Concerns
The Rescue Board and Consumer Protection Board emphasized the importance of reliable safety testing protocols, risk mitigation measures, and clear responsibility chains for fires or failures. For example, the insurance companies are evaluating the risks of lithium-ion battery fire on a case-by-case basis (Workshop 2025). These concerns are heightened by the physical characteristics of repurposed batteries—potentially degraded, non-standardized, and lacking in full traceability. This results in a high-risk perception among regulatory bodies and emergency services. Furthermore, according to the Rescue Board, extinguishing such fires is more complicated. Traditional fire suppression systems that work by reducing oxygen levels are ineffective in these fires. Water-based systems also cannot control the intense heat and flammable gases produced during a lithium-ion battery fire. Hence, the important realm to focus on is the effective extinguishing agent.
As of spring 2025, the Rescue Board of Estonia elaborated the guiding document “Ensuring essential fire safety requirements in buildings when installing battery banks” (in Estonian), where the most vital safety requirements for the battery room are being outlined, such as the minimum fire compartment of 30 min, presence of the fire door, the establishment of the optimal temperature (5-25) (which may vary depending on the manufacturer) and the separate entrance to the room (e.g. garage or boiler room). As of April 2025, this guiding document is not obligatory to follow and is currently gathering feedback from stakeholders. However, from the viewpoint of the Rescue Board, it has the potential to be developed into a detailed technical standard and form the basis for the proposal on the compilation of a national standard.
Insufficient Technical Infrastructure
As confirmed by both Nordic interviews and Estonian stakeholders, Estonia currently lacks battery testing and refurbishment infrastructure, which is essential for reliable assessment and preparation of second-life systems. This creates a bottleneck for local deployment and inhibits confidence among authorities.
Second-life Battery Quality: Data, Oversight and Classification Barriers
According to the Battery Regulation (2023), the digital passport requirement will apply from 2027. It hence does not apply to the batteries, which are on the market now. The lack of access to OEM battery data was identified as a significant technical and legal barrier. Without this information, it is difficult to assess battery health, fire risk, and repurposing feasibility. Furthermore, the stakeholders discussed that access to the maintenance and accident data is crucial to ensure that the battery is in proper condition for the second use. In the words of one of the interviewees,
“the biggest problem at the moment is that we do not know what we are installing with the second-hand battery, whether it is a car battery or any other battery” (Workshop 2025). The other added, “Knowledge is needed on the battery history, the car dealers may not know whether the car has been in an accident or not, whether it is being properly repaired “around the corner”, and we do not yet know what effect such an accident might have had on the battery” (Workshop 2025).
There might be a need for national regulations that would provide an overview of which EV has been involved in the accident and which has not. It remains unclear how to obtain this data and which stakeholders would be the primary owners of this data (car manufacturers, battery manufacturers, car dealers, or insurance companies. Furthermore, workshop discussions revealed that the oversight of data accessibility is important, however, remains uncertain which institutional body would perform this oversight in Estonia.
Furthermore, as noted during the discussions, there is a clear need for consensus among the EU member states in terms of the access to data from the Battery Management System (BMS). The Battery Regulation stipulates that the data should be accessible, however, the details should be jointly agreed upon between the member states to avoid confusion among the industry representatives.
A key barrier in Estonia is the unclear hazard classification of end-of-life and second-life EV batteries. It remains ambiguous whether these batteries are to be treated as hazardous waste, non-hazardous waste, or reclassified as products post-testing. This classification directly affects handling, transport, storage, and reuse regulations. If deemed hazardous waste, stricter safety protocols apply, limiting repurposing opportunities. However, Estonia currently lacks standardized criteria and institutional procedures to support safe reclassification and reuse, creating regulatory uncertainty for second-life applications.
Market
Stakeholders outlined that currently there are few incentives from the business perspective to use the second-life batteries as opposed to the first-life ones. The second-life batteries do not provide price advantages and might sometimes even be more expensive, especially considering the investment needed for testing their state of health. As noted in the interviews, “I have communicated (…) with a Finnish startup (…), who started out repurposing Tesla Model S batteries (…) and they have shifted to using brand new batteries from repurposing due to the shortage of the second life EV batteries. (…)The prices for the new batteries have come down quite a bit so that it doesn’t really make sense financially to repurpose those batteries and they have really shifted their focus on creating batteries from scratch now” (Interview A 2024).
As revealed during discussions, companies might be repurposing second-life batteries for the sake of “green” activity implying it might be beneficial rather for their image than bring revenues. As mentioned by one of the interviewees: “It only boils down to if it (i.e. second-hand battery) can provide something extra” (Interview A 2024). Therefore, the existence of the business model incentives is important. Financial incentives or market frameworks that support repurposing over recycling or disposal, including government support for circular economy initiatives or public procurement that favours reused components are needed. The Battery Regulation provides specific targets for the recycling of the batteries but does not foresee similar measures for repurposing.
Finally, the current EV penetration rate in Estonia is modest, with used EV batteries for domestic sources still relatively scarce. Approximately 2-3 tones per year of used batteries are received by responsibility organisations. The percentage of EV-cars in use is below 5%. As the interviews demonstrate, the solid incentives for the purchase of an EV-car in the Nordics were in place, which in turn led to massive adoption. While in Estonia the desire of people to own an EV seems to increase year by year[1], two thirds of those who do not own an EV today responded that EVs are too expensive, slightly more than a third claim they do not have a suitable charging station, and they believe that the driving range of the cars is still too small (Lõunaeestlane 2024).
[1] Approximately 28% of respondents plan to buy an EV in the upcoming 5+ years, a third do not intend to buy it, and 40% are still unsure (Lõunaeestlane 2024).
Opportunities for Nordic-Estonian Cooperation
The Nordic countries provide valuable models for testing, classification, and fire safety practices in second-life battery repurposing. Estonian stakeholders showed interest in adapting such practices but stressed the need for local testing, standardization, and demonstration before adoption.
This study highlights a mix of opportunities and systemic barriers that need to be addressed for such solutions to take root in the Estonian context. We provide the main consolidated conclusions drawn from discussions with Estonian stakeholders. They formed the basis for the overview of technical needs and opportunities and the recommendations that can accessed in this Project Brief.
We greatly appreciate the time and valuable insights that Estonian stakeholders offered us on this topic. We would like to thank the Rescue Board, Ministry of Climate, Consumer Protection Board, Producer Responsibility Organizations, energy storage companies and research institutions contributing to this report by participating in co-creation events.