ARA’s Testimony on SB 26-003
Dear Committee Chair Cutter, Vice Chair Ball, and Members of the Committee,
The Automotive Recyclers Association (ARA) appreciates the opportunity to provide testimony on SB 26-003, which is a bill seeking to establish a responsible end-of-life vehicle battery framework. ARA supports the intent of this legislation and finds it necessary to develop a workable framework to address the responsible end-of-life management of propulsion batteries.
Automotive recyclers are primary participants in Colorado’s vehicle recycling ecosystem and are responsible for sourcing, depolluting, and maximizing the useful life of every vehicle and its components – thereby creating a self-sufficient circular economy. Each year, approximately 330,000 vehicles reach end-of-life in Colorado, and professional automotive recyclers process the majority of them in compliance with local, state, and federal law. As electric vehicles and high-voltage vehicle batteries become ever more common in the marketplace, recyclers are increasingly the first downstream custodians of high-voltage propulsion batteries.
Today, the downstream propulsion battery market lacks transparency, consistent pricing signals, and clear responsibility for stranded or negative-value batteries. In many cases, the cost to safely store, transport, or recycle a battery may exceed its economic value. Without a clear statutory framework, this creates significant safety risks and economic uncertainty for secondary handlers, while also undermining broader environmental objectives.
Over the past several months, ARA has participated in a multi-stakeholder working group that includes vehicle manufacturers, recyclers, and environmental organizations. That process has produced a balanced framework designed to improve safety, provide market stability, and ensure that batteries are managed according to the highest and best use.
A successful end-of-life battery framework should:
§ Codify a battery management hierarchy that prioritizes reuse, repurposing, and remanufacturing before recycling.
§ Require producers to provide easily interpretable and accessible state of health (SOH) and state of charge (SOC) information to ensure safe handling and informed downstream decision-making.
§ Establish a clear producer backstop for stranded or negative-value batteries, ensuring that responsibility is assigned when no viable secondary market outlet exists.
§ Preserve a competitive market for battery reuse and recycling, rather than unintentionally consolidating control or limiting lawful market activity.
ARA respectfully requests targeted amendments to SB 26-003 to reflect this consensus-based framework. These refinements will strengthen the bill, reduce unintended consequences, and ensure that the legislation is durable and workable in real-world market conditions.
ARA remains committed to working collaboratively with all stakeholders and the Committee to ensure Colorado adopts a framework that enhances safety, supports environmental goals, and promotes long-term market stability
