A coalition of environmental and clean technology organizations has released a joint letter ahead of the Circular Economy Act, urging policymakers to establish concrete mechanisms for expanding Europe’s battery recycling and material recovery infrastructure.
The groups emphasize that recovering materials from discarded batteries represents a crucial pathway for securing critical raw materials in a sustainable and resilient manner. By increasing recycling capacity within Europe, the continent can diminish its reliance on imported critical minerals and strengthen supply chain independence. However, the European battery recycling sector currently faces significant scaling challenges, with more than half of existing recycling capacity described as vulnerable.
A central concern raised in the letter involves the export of black mass—a concentrate rich in critical raw materials derived from shredded lithium-ion batteries. Europe currently handles the initial processing of battery waste domestically but ships most black mass to foreign refineries for final material extraction. Data indicates that at minimum 60 percent of Europe’s black mass leaves the EU, though organizations note this figure likely understates the true amount due to untraceable shipments using alternative customs classifications. This material outflow is characterized as undermining European strategic autonomy, transferring high-value manufacturing employment overseas, and weakening circular economy principles and environmental standards.
The organizations contend that European recyclers operate under financial strain and elevated energy expenses, necessitating stronger policy support and market signals to justify investment in domestic refining infrastructure. The forthcoming Circular Economy Act, according to the letter, must directly address black mass leakage while simultaneously fostering investment in EU-based refining capacity. The coalition argues these regulatory changes are essential for establishing effective material recovery systems that maintain valuable materials and associated economic benefits within Europe.
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