Crisis of Critical Raw Material Leakage
An alliance including prominent organizations such as Transport & Environment (T&E), Recharge, Clean Tech for Europe, and EIES has sent a joint letter demanding concrete actions within the upcoming Circular Economy Act. The alliance aims to address the challenges facing the battery recycling sector in Europe, where estimates indicate that more than half of the continent's current recycling capacity is at risk.
The core problem lies in the shortage of available Feedstock for European plants; at least 60% of Black Mass—the concentrated material rich in critical minerals resulting from the shredding of lithium-ion batteries—is exported outside the European Union for final processing. This structural leakage leads to the loss of high-value jobs and weakens Europe's strategic autonomy in securing critical minerals.
Legislative Demands of the Alliance
To ensure valuable materials remain within the continent, the alliance has proposed a set of regulatory measures that the new law should include:
- Export Restrictions: Evaluating the imposition of duties or tariffs on the export of Black Mass and unprocessed waste.
- Standardization: Establishing a unified technical definition for Black Mass at the EU level and setting strict End-of-Waste criteria to ensure the quality of recycled materials.
- Customs Coding: Introducing a unified code within the Combined Nomenclature (CN) for Black Mass and its derivatives to facilitate tracking and oversight.
Strengthening Industrial Capabilities
In addition to regulatory restrictions, the alliance emphasizes the need to incentivize investment in local refining capabilities through:
- Recycled Content Incentives: Linking local incentives to the recycled content targets stipulated in the European Battery Regulation.
- Support for Extended Producer Responsibility (EPR) Schemes: Introducing a bonus-malus structure that grants preference to materials refined and recovered within the European Union.
- Facilitating Internal Shipments: Reviewing the Waste Shipment Regulation to simplify the transport of waste containing critical minerals between EU countries, exempting them from complex prior notification procedures.
- Financial Support: Providing support for capital and operational expenditures (Cap-Ex & Op-Ex) for recycling projects, with priority given to local refining facilities.
These demands come at a time when recyclers in Europe are suffering from financial pressures and high energy costs, making political intervention an urgent necessity to ensure the sustainability of the continent's technical supply chains.