MIL-OSI Europe: Answer to a written question – Measures to retain and recycle black mass from electric vehicle batteries within the EU – E-001428/2025(ASW)

Source: European Parliament

For all waste destined for disposal, or in the case of hazardous and most mixed waste destined to recovery, the prior notification and consent procedure applies.

This means that an operator planning such shipments needs the prior consent of all authorities from the countries concerned (from origin to destination, including transit) before the shipment can take place.

The new Waste Shipment Regulation[1] will simplify this process and move away from a paper-based approach to an electronic one. A central EU system will ensure the smooth operation of this exchange from May 2026.

The Commission will develop a central hub that will allow the exchange of information and documents between the central system and local system operated by some competent authorities as well as software offered by commercial software providers.

The Implementing Act on interoperability of systems for electronic submission and exchange of information and documents is intended to be adopted in the coming weeks.

Related to recycling, Article 72(3) of the Batteries Regulation[2] sets the clear and strict condition that waste batteries or fractions thereof exported from the Union shall only count towards the fulfilment of obligations, efficiencies and targets laid down in Articles 70 and 71 of the Batteries Regulation if the exporter of the waste batteries or fractions thereof provides documentary evidence approved by the competent authority of destination that the treatment took place in conditions that are equivalent to those required by the Batteries Regulation and in accordance with other Union law regarding human health and environmental protection.

Together those provisions will improve the economic model for recycling black mass within the EU.

  • [1] Regulation (EU) 2024/1157 of the European Parliament and of the Council of 11 April 2024 on shipments of waste, amending Regulations (EU) No 1257/2013 and (EU) 2020/1056 and repealing Regulation (EC) No 1013/2006, OJ L, 2024/1157, 30.4.2024.
  • [2] Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC, OJ L 191, 28.7.2023, p. 1-117.
Last updated: 1 July 2025

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