Ahead of the Circular Economy Act, a joint letter from T&E, Recharge, Clean Tech for Europe and EIES calls for concrete measures to support the effective scaling of Europe’s material recovery and recycling capacity.
📌 The Core Development
Recovering materials from end-of-life batteries is a key means to secure much needed critical minerals (CRMs) resiliently and sustainably. With increased recycling, Europe can reduce imports of CRMs, in turn reducing external dependencies. However, Europe’s battery recycling industry is struggling to scale, with over half of Europe’s battery recycling capacity currently at risk . The Circular Economy Act must introduce measures to help scale Europe’s battery recycling capacity.
European battery recyclers lack the needed feedstock. Europe currently preprocesses most battery waste domestically but exports the majority of black mass — CRM rich concentrate from shredded lithium-ion batteries — for final refining abroad. Analysis shows at least 60% of Europe’s black mass is leaving the EU, with this likely only the tip of the iceberg, and lots more black mass leaving the EU, hidden in different customs codes, and unable to be traced. This structural leakage undermines EU strategic autonomy, shifts high-value jobs abroad, weakens circularity and environmental protection.
🔍 Background & Sector Context
Faced with financial pressures and higher energy costs, European recyclers also need strong political and demand signals in Europe, in order to encourage investment in EU refining capacity. This will be key to ensuring we can process and keep valuable materials in Europe.
As a result, the upcoming Circular Economy Act must urgently address Europe’s black mass leakage problem by:
📊 Industry & Real-World Impact
The CEA must also support the scaling of European recycling capacity, encouraging investment in EU refining capacity with:
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🔮 Strategic Outlook & What Lies Ahead
The Circular Economy Act can achieve a shift in mindset, and deliver much needed tools to support Europe’s battery recycling industry, securing effective material recovery capacity in Europe.
