Eurometaux and other trade groups call on EU legislators to address barriers hindering swift shipment of end-of-life lithium-ion batteries for recycling; groups call for valuable battery materials stay in Europe to promote a circular battery value chain

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November 8, 2023 (press release) –

3rd November 2023

We, the undersigned European associations representing our members in the battery,
their raw materials, battery recyclers and electromobility ecosystems, are calling on the
legislators to address current barriers to the swift shipment of end-of-life Lithium-ion
batteries and their intermediate waste streams, i.e black mass, under the last stages of
trilogue negotiations for the EU Waste Shipment Regulation.

From the adoption of the EU Strategic Action Plan on Batteries in 2019 and the EU Batteries
Regulation to the proposal for the Critical Raw Materials Regulation, the EU has paved the
way for building a full battery and raw materials value chain, in particular by setting battery
recycling and material recovery targets. This objective is critical to ensure that valuable battery
materials stay in Europe and serve future products while making the continent less dependent
on virgin material imports from the third countries.

Given the scarcity of critical raw materials used in net-zero technologies, we believe the EU
should prioritise removing any barriers to the rapid and optimal recycling of Lithium-ion
batteries and their intermediate waste streams within the Union in line with its objective to
establish a true circular battery value chain.

Yet today, shipping end-of-life Lithium-ion batteries and their black mass within the EU is a
cumbersome, lengthy and costly process that impedes true intra-EU competition for recycling
services. The main reasons for this bottleneck are Member States’ divergent interpretation of
such batteries’ waste codes as well as the unpredictable and rigid administrative procedures
for receiving a green light to the shipment of battery black mass.

For the EU to start becoming resilient and competitive in the battery recycling, we need the
EU policy-makers to harmonise the interpretation of waste batteries & battery black masses
shipments across its territory and significantly simplify related shipment procedures, allowing
for example for a fast track shipments to pre-consented facilities. Failing to do so will prevent
the EU from meeting its own battery material recycling targets and addressing the high
incoming volumes of end-of-life battery volumes expected by in the next decade.
We therefore call on you to add a new provision that would:

  • Secure an appropriate update of the EU List of Waste, with dedicated waste codes for lithium-ion batteries and their intermediate waste streams (“black masses”), including a hazardous waste classification for black masses
  • Ensure that these codes are fully harmonised at EU level
  • Define a simpler, faster and more predictable shipment procedure for such waste for recycling within the Union.



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