The EU Critical Raw Materials Act (CRMA) represents a pivotal legislative framework aimed at securing the bloc’s access to essential materials necessary for the green and digital transitions. Among its core objectives is the enhancement of battery recycling to recover strategic raw materials, aligning with broader circular economy goals. The CRMA sets explicit targets for material recovery, including a 15% cobalt recycling rate from waste by 2030, reflecting the urgency of reducing reliance on external supply chains. This article examines how the CRMA intersects with existing EU battery recycling regulations, the implications for supply chain security, and the role of cross-border partnerships in achieving these objectives.

Battery recycling is a critical component of the EU’s strategy to mitigate supply risks for materials like lithium, nickel, cobalt, and graphite. The CRMA complements the EU Battery Regulation, which mandates stringent recycling efficiency and material recovery rates for end-of-life batteries. By setting specific targets for cobalt and other critical materials, the CRMA reinforces the Battery Regulation’s focus on closing the loop in battery production. The 15% cobalt recovery target by 2030 is not arbitrary; it reflects the material’s high economic importance and supply risk, as classified under the EU’s critical raw materials list. Achieving this target requires harmonized efforts across member states, particularly in scaling up recycling infrastructure and optimizing collection systems.

Supply chain security is a central theme of the CRMA, driven by the EU’s dependence on imports for key battery materials. Over 80% of the EU’s cobalt supply is sourced from non-EU countries, primarily the Democratic Republic of Congo, where concerns over ethical mining practices and geopolitical instability persist. By mandating domestic recovery of cobalt and other materials, the CRMA reduces exposure to external vulnerabilities. The act also encourages diversification of supply through recycling, which is less susceptible to geopolitical disruptions than primary extraction. This approach aligns with the EU’s broader ambition to achieve strategic autonomy in critical sectors, including electric mobility and renewable energy storage.

The CRMA’s emphasis on cross-border recycling partnerships is another key aspect of its strategy. Given the uneven distribution of recycling capabilities across member states, collaboration is essential to meet recovery targets. The act promotes the development of transnational recycling networks, where countries with advanced recycling technologies can process waste streams from less-equipped nations. For example, Germany and Belgium, which host some of the EU’s largest battery recycling facilities, could play a central role in processing end-of-life batteries collected in Southern or Eastern Europe. Such partnerships are facilitated by the CRMA’s provisions for shared infrastructure funding and streamlined waste shipment regulations.

The interplay between the CRMA and the EU Battery Regulation creates a cohesive regulatory environment for battery recycling. While the Battery Regulation sets the technical standards for recycling processes, the CRMA provides the strategic impetus for material recovery. Together, they ensure that recycling efforts are not only efficient but also aligned with the EU’s critical material priorities. For instance, the Battery Regulation’s requirement for 70% recycling efficiency for lithium-ion batteries by 2030 is complemented by the CRMA’s focus on recovering specific materials like cobalt. This dual approach maximizes both the quantity and quality of recycled outputs.

Implementation challenges, however, remain. Meeting the 15% cobalt recovery target will require significant investments in hydrometallurgical and pyrometallurgical recycling technologies, which are currently limited in scale. Additionally, improving collection rates for end-of-life batteries is critical; without sufficient feedstock, even the most advanced recycling facilities cannot operate at full capacity. The CRMA addresses these challenges by supporting research and innovation in recycling technologies and incentivizing better collection systems through producer responsibility schemes.

The CRMA also has implications for the competitiveness of the EU’s battery industry. By securing access to recycled materials, European battery manufacturers can reduce costs and enhance sustainability credentials, which are increasingly important in global markets. Recycled cobalt, for example, typically has a lower carbon footprint than mined cobalt, aligning with the EU’s climate goals. Furthermore, the act’s focus on strategic autonomy reduces the risk of supply shortages, ensuring stable production flows for battery makers.

In conclusion, the EU Critical Raw Materials Act represents a strategic leap forward in integrating battery recycling into the bloc’s raw material security framework. By setting clear recovery targets for cobalt and other critical materials, the act reinforces the EU Battery Regulation and strengthens supply chain resilience. Cross-border recycling partnerships will be essential to achieving these goals, leveraging the strengths of individual member states. While challenges in technology and collection systems persist, the CRMA provides a robust foundation for scaling up recycling efforts. As the EU moves toward its 2030 targets, the act will play a central role in ensuring that battery recycling contributes meaningfully to both circular economy principles and strategic autonomy.