Second-life batteries could help scale energy access in Africa, but efficient cross-border movement will be critical to deployment at scale

Most second-life batteries are manufactured, assembled, and retired in different markets from where they are eventually redeployed. As a result, they must move through customs, transport, and regulatory systems that were not originally designed with battery reuse in mind. This creates uncertainty around product classification, testing requirements, certification processes, and transport procedures, all of which can introduce delays and additional costs.

Yet solving these challenges could unlock a more affordable pathway for scaling mini-grids and expanding energy access across Africa.

CrossBoundary’s Mini-Grid Innovation Lab, together with Vittoria Technology and with support from the Transforming Energy Access platform, launched a real-world import and export simulation tracking the movement of second-life batteries and cells across multiple African markets.

Launched in November 2025, the simulation uses batteries manufactured and assembled in Uganda by Soleil Power and will continue through August 2026. Since then, the batteries have moved through Rwanda, Burundi, and Tanzania to better understand how existing systems handle second-life battery products in practice.

1. Existing lithium-ion frameworks may already accommodate second-life batteries

Existing regulatory systems in Uganda, Rwanda, and Tanzania appear capable of accommodating second-life batteries, provided products are tested, documented, and clearly labeled.

So far, the same HS code (8507.60) was used for both first-life and second-life lithium-ion batteries. In practice, authorities have generally treated the products as standard lithium-ion batteries rather than creating entirely separate processes for second-life products.

Across Uganda, Rwanda, Burundi, and Tanzania, inspections and clearance processes focused primarily on product condition, testing documentation, and technical specifications rather than explicitly distinguishing between first-life and second-life battery cells. Notably, the Material Safety Data Sheet (MSDS) was the only shipment document explicitly referencing the use of second-life cells.

The initial observations suggest that the absence of dedicated second-life battery regulations may not necessarily prevent early-stage deployment, particularly where existing lithium-ion frameworks can be applied. The simulation also highlights the need for clearer and more harmonized guidance as battery reuse markets scale.

2. Documentation has played a major role in reducing delays and improving border clearance predictability throughout the simulation

UNBS testing certification from Uganda was accepted across multiple borders and often reduced the need for additional testing or verification. In Rwanda, for example, UNBS test reports were accepted in place of a Certificate of Analysis during customs clearance.

We have also observed that clearly labeled products and readily available technical documentation helped streamline inspections. In Tanzania, attaching technical specification labels directly to batteries reduced the need for inspectors to request supporting documents such as user manuals or datasheets.

Import and export agents reported that carrying supporting documentation, including warranties, certificates of origin, testing certificates, and technical datasheets, often accelerated approvals even when not formally required.

At the same time, documentation requirements were not always predictable or consistent. Delays in obtaining certification in Uganda also revealed inconsistencies in documentation and testing requirements, including repeated application resubmissions and requests for documentation that had not initially been specified.

Taken together, these findings point to a broader market challenge: the absence of standardized documentation pathways for second-life battery movement across regional markets.

3. Smaller shipments currently move more easily through existing systems

The simulation suggests that low-value battery shipments currently face fewer compliance requirements than larger commercial consignments.

In Burundi, shipments valued below US$2,000 did not require Pre-export Verification of Conformity (PVOC) certification or additional third-party testing. Similarly, Tanzania waived PVOC requirements for shipments below US$5,000, although destination inspections still applied.

However, once shipments exceed these thresholds, additional certification requirements can increase costs, documentation requirements, and inspection complexity. In Tanzania, for example, higher-value shipments require PVOC certification from approved inspection companies, with financial penalties applied to non-compliant cargo.

These requirements could become a barrier to larger-scale commercial deployment unless certification processes and regional standards become more aligned. While pilot shipments and smaller consignments moved relatively smoothly through the simulation, additional testing and certification requirements may create greater friction for higher-volume battery trade across regional markets.

4. Existing systems are functioning, but they are not yet designed for battery reuse

The simulation also highlighted the extent to which existing customs and standards processes were adapted in practice to accommodate battery shipments.

Documentation and tracking requirements varied across markets, reinforcing the lack of a harmonized regional approach to battery reuse. Rwanda required electronic billing declarations prior to export, Burundi electronically tracked imported batteries before verifying their exit during export processing, while Tanzania relied heavily on physical inspection procedures to verify product condition and technical specifications.

In several cases, supporting documents were not formally required but still played an important role in facilitating inspections and approvals. Import agents also noted that batteries manufactured within East Africa and supported by recognized testing certificates generally moved more smoothly through border processes.

Many of the systems needed to support second-life battery trade already exist across East African markets. However, these systems currently operate within broader lithium-ion regulatory frameworks rather than processes specifically designed for battery reuse.

As second-life battery markets grow, clearer regional regulatory guidance and more standardized procedures may be needed to improve predictability for importers, developers, and investors.

The observations from the initial phases of the simulation suggest that technical feasibility is no longer the primary barrier to second-life battery deployment in Africa. Instead, regulatory fragmentation, inconsistent documentation requirements, and limited institutional familiarity with battery reuse are emerging as key constraints to scale.

At the same time, the findings indicate that existing systems may provide a stronger foundation than previously assumed. Several markets were able to process second-life battery shipments using existing lithium-ion frameworks, particularly where products were properly tested, documented, and labeled.

For policymakers and regulators, this highlights an opportunity to develop clearer and more harmonized approaches to battery reuse across regional markets. For development funders and ecosystem partners, the findings reinforce the importance of supporting:

• harmonized standards and certification pathways
• battery traceability and documentation systems
• local testing and inspection capacity
• regional coordination on battery reuse frameworks
• pilot projects that generate operational evidence for regulators and industry

The early findings also suggest that relatively targeted interventions could reduce market friction and support larger-scale commercial deployment of second-life batteries across African markets. These include regional testing recognition, harmonized documentation standards, regulator capacity-building, and shared certification frameworks.

The challenge is not the absence of regulatory systems altogether, but the lack of coordination, consistency, and familiarity needed to support battery reuse at commercial scale. As battery reuse markets continue to develop globally, Africa has an opportunity to shape practical, scalable approaches that support both circular economy objectives and expanded energy access.

Improving the predictability and efficiency of cross-border battery movement may prove just as important as advances in battery technology itself.

The CrossBoundary Mini-Grid Innovation Lab will continue to track the movement of second-life batteries across additional African markets, helping build the operational evidence base needed to support more harmonized and investment-ready battery-reuse ecosystems. As the simulation progresses, the batteries are now heading toward Malawi, Zambia, Angola, DRC, Congo, Cameroon, Nigeria, and Benin.