EU Battery Waste Codes and the Standardized Methodology for Recycling Efficiency and Recovery Targets

The EU Battery Regulation 2023/1542 lays out a comprehensive legal framework covering the full battery lifecycle—from design and production to end-of-life collection, recycling, and material recovery. Two new delegated acts released in 2025 address key technical aspects of this regulation. These Decision enters into force 20 days after their publication in the Official Journal of the European Union and apply 18 months after it enters into force:

• A Delegated Decision amending the List of Waste (LoW) under Commission Decision 2000/532/EC to reflect the complexities of battery-related waste.

• A Delegated Regulation establishing the methodology for calculating and verifying recycling efficiency (rRE) and material recovery rates (rRM).

Battery Waste Classification in the EU List of Waste Codes

The Delegated Decision amending Commission Decision 2000/532/EC introduces a new level of precision in identifying and managing battery-related waste. Previously, batteries were grouped under a limited number of codes, with many streams classified together, which is no longer the case. 

Specific waste codes now exist for each major battery chemistry, including lithium, nickel, zinc, and sodium-based batteries. For example, lithium-based batteries fall under code 16 06 07*, while sodium-based waste streams are split between codes 16 06 10* (containing hazardous substances) and 16 06 11* (sodium-sulphur batteries).

Alkaline batteries, which were once widely considered non-hazardous, are now reclassified as hazardous under code 16 06 04*. This classification is based on up-to-date composition data and CLP Regulation criteria. This shift aligns classification with modern scientific assessments and aims to minimise uncontrolled environmental exposure to heavy metals and caustic electrolytes.

In addition to spent batteries, the amended list introduces classifications for battery manufacturing waste. New codes distinguish between hazardous and non-hazardous materials for each battery type, enabling better management of production offcuts, electrode slurries, and electrolyte residues. For instance, hazardous lithium-based manufacturing waste is categorised under code 16 06 24*, while non-hazardous variants fall under code 16 06 25.

Intermediate recycling fractions, particularly black mass, containing critical raw metals like cobalt, lithium, and nickel, are recovered during early-stage recycling. Classified under the new 19 14 series (e.g., 19 14 02* for lithium-based black mass), these streams are deemed hazardous due to the presence of reactive or toxic substances. This classification brings black mass under strict regulatory controls for transport, treatment, and transboundary shipment.

Municipal collection systems are also affected. Previous catch-all codes, such as 20 01 33* and 20 01 34, have been replaced. Now, separately collected lithium-based batteries from households must be labelled under 20 01 43*, and mixed hazardous batteries fall under 20 01 42*. These changes address the growing fire risks associated with lithium-ion batteries in consumer waste streams and ensure that they are properly treated.

Export Restrictions on Black Mass under Basel Convention Rules

The classification of black mass as hazardous triggers significant regulatory consequences under international law. Specifically, it now falls under Annex VIII of the Basel Convention, which is implemented in the EU through Regulation (EC) No. 1013/2006. This prohibits the export of black mass to non-OECD countries, effectively ending the practice of outsourcing early-stage recycling to countries with lower environmental oversight.

Recyclers must now retain black mass within the EU or ship it only to other OECD countries, with prior informed consent procedures in place. Shipments must be accompanied by detailed documentation, ideally supported by battery passport data, that specifies the chemical composition, hazard profile, and final destination. The aim is to ensure that critical raw materials, such as lithium and cobalt, remain within the EU economy, enabling secure and environmentally responsible recycling and reuse.

Standardised Methodology for Recycling Efficiency and Material Recovery

Under the Delegated Regulation supplementing Article 71(4) of Regulation (EU) 2023/1542, the European Commission has introduced a consistent methodology for calculating recycling efficiency (rRE) and material recovery rates (rRM). This regulation ensures that all recyclers apply the same metrics, making performance data both verifiable and comparable across Member States.

Recycling efficiency (rRE) measures the percentage of the total input battery mass that is recovered into usable materials. The formula is:

Input mass includes all components entering the recycling process, batteries, casings, cables, and electrolytes, while output mass counts only those fractions intended for industrial use. Residues, such as slag with a recoverable metal content of less than 50% and any forms of energy recovery, are explicitly excluded. Importantly, this efficiency must be calculated separately for each battery chemistry: lead-acid, lithium-based, nickel-cadmium, and others.

Material recovery rate (rRM) focuses on five target materials (TM): cobalt, lithium, nickel, copper, and lead. This indicator calculates the proportion of each element successfully recovered into a market-ready, industrial-grade form. (e.g.,Li2 CO3 99.5% purity for lithium,Co3O4 99.8% purity for cobalt)

Where TM is the target material. Recovery is measured only at the point when the substance meets specific technical specifications, excluding any partially processed intermediates. Cadmium and mercury, due to their toxicity, must be immobilised or safely disposed of and are not considered part of rRM but are still reportable under separate criteria.

Documentation, Reporting, and Verification Procedures

Starting in 2026, all recycling operators will be required to submit detailed annual reports using standardised templates. These reports must include:

• Mass balance of input, intermediate, and output fractions

• Composition data for each battery chemistry processed

• Material recovery and recycling efficiency calculations

• Handling procedures for hazardous residues, such as cadmium and mercury

The first recycler, the facility initially receiving waste batteries, is responsible for coordinating the data across all downstream steps, ensuring traceability even when treatment occurs in multiple locations or Member States.

Competent authorities within each Member State will manage verification. These authorities will cross-check reports for completeness, consistency, and accuracy, conducting audits and site inspections where necessary. Self-audits by external certified entities are permitted and encouraged, although regulatory authorities retain the final decision-making power. The regulation requires that all documentation be submitted electronically and formatted to allow data interoperability across jurisdictions.

Implementation Challenges for Stakeholders

While the updated regulations strengthen environmental protection and critical material recovery, their implementation presents considerable challenges.

For recyclers, especially small to medium-sized enterprises (SMEs), the new waste codes and calculation methodologies require investments in analytical capabilities, tracking systems, and, in many cases, process upgrades to meet ambitious recovery targets. Transitioning from generic waste tracking to chemistry-specific hazardous waste handling, especially for newly classified materials like alkaline batteries and black mass, will require new permits, training, and reporting workflows.

Member States must adapt their permitting and enforcement structures to reflect the expanded waste codes and ensure their inspection teams are equipped to verify complex material flows and documentation. As annual reporting and verification become mandatory, national authorities face an increased administrative and technical workload.

Finally, the battery supply chain must recalibrate its logistics, labelling, and safety procedures to handle newly classified hazardous streams, most notably black mass and municipal lithium batteries. The 18-month transition period offers a limited time to realign infrastructure, harmonise data systems, and train personnel across the entire value chain.

The revised EU waste codes and calculation methodologies are not simply technical adjustments, but they are foundational shifts in how the EU governs battery waste and material recovery. These regulations bring enforceability and accountability to the recycling sector, aligning with the EU’s strategic goals on resource security and a circular economy. Implementation will depend on proactive industry engagement, building regulatory capacity, and cross-border collaboration. 

At Battery Associates (B.A), we offer comprehensive compliance solutions for European battery regulations, guiding you through the industry's evolving landscape. Our expert team offers tailored solutions and insights to navigate these requirements seamlessly. Reach out to us for detailed support and information on meeting compliance standards.

About the Author

Gokulakrishnan Kalaivanane

Research Analyst - Battery Associates

Gokul is currently a Research Analyst at Battery Associates. He holds a master's degree in energy engineering from Politecnico di Milano and a bachelor's degree in mechanical engineering. His expertise lies in power generation, renewable energy, and energy storage. Gokul is passionate about battery technology and its ability to fulfill the changing needs of the energy sector. He is particularly interested in battery energy storage systems (BESS), Electric vehicles (EV), and promoting a circular economy throughout the battery value chain.