A coalition including Transport & Environment, Recharge, Clean Tech for Europe, and EIES has issued a joint letter ahead of the Circular Economy Act. The organizations are urging policymakers to implement concrete measures to support the scaling of battery recycling and material recovery capacity across Europe.
The industry currently faces significant challenges, with over half of Europe's battery recycling capacity at risk. A primary issue is the lack of feedstock, as at least 60% of black mass—a concentrate derived from shredded lithium-ion batteries—is exported outside the European Union for final refining.
This structural leakage of materials hinders the region's strategic autonomy and results in the loss of high-value jobs. The coalition argues that European recyclers require stronger political and demand signals to overcome financial pressures and high energy costs, which are currently deterring investment in local refining.
To address these issues, the group is calling for the Circular Economy Act to include specific provisions that prevent the export of black mass and incentivize the development of domestic refining infrastructure. These steps are presented as essential for maintaining valuable materials within the European market.






