EBRA’s Key Regulatory Priorities and Working Group Activities in 2026

As part of EBRA’s ongoing commitment to representing the interests of the European battery recycling industry, EBRA’s Technical Adviser Johan van Peperzeel has been actively participating in a range of technical working groups and stakeholder discussions organised by the European Commission, European Chemicals Agency, and other relevant organisations.

Since January 2026, the focus has been on monitoring and contributing to technical developments linked to the implementation of the EU Battery Regulation and related legislation. While EBRA continues to engage across a broad range of topics, priorities are carefully managed to ensure resources are focused where they matter most for EBRA members.

Below is an overview of the main subjects currently being followed by EBRA.

1. Substances of Concern (WSP/ECHA)

Within the WSP/ECHA discussions, work is ongoing to identify substances of concern that could potentially hamper the recycling of lithium-ion batteries. EBRA continues to monitor these discussions closely.

EBRA’s position remains clear: the European battery recycling industry already operates established and highly regulated processes that safely manage end-of-life batteries in compliance with existing European legislation. Together with the EBRA Board, the view is that current recycling systems are functioning effectively and should be recognised as such within future policy discussions.

2. Battery Digital Passport

EBRA has participated in several meetings relating to the Battery Digital Passport. From a recycling perspective, the proposed framework is expected to provide recyclers with improved access to technical information needed for the safe and efficient treatment of batteries, battery packs, and cells.

One area of increasing attention concerns access to commercially sensitive information. Some OEMs, including vehicle manufacturers developing their own recycling operations, have raised concerns about competitors gaining access to proprietary data through the system. EBRA continues to follow these discussions to ensure recyclers maintain access to the information necessary for effective end-of-life treatment while balancing confidentiality considerations.

3. DIWASS and Digital Waste Shipment Procedures

Since 21 May 2026, notifications for cross-border shipments of batteries must be submitted digitally through the DIWASS system. This requirement also applies to Annex VII material.

Implementation timelines differ across EU Member States. In countries such as the Netherlands, the Annex VII digitalisation process has been delayed until the end of 2026.

As batteries remain classified as hazardous waste in most EU countries, the transition itself is manageable. However, the practical functioning of the system between exporting, transit, and receiving countries remains an important point to monitor.

4. New EURAL Codes and Hazardous Waste Classification

New EURAL waste codes for lithium-ion and lithium batteries are now being introduced. More significantly, all battery chemistries — including alkaline batteries — are expected to be classified as hazardous waste.

This development has important operational implications for recyclers. In particular, EBRA members are encouraged to review their environmental permits carefully, as hazardous classification may impact the permitted annual tonnage of batteries entering facilities. In some cases, permit updates or amendments may be required.

5. Delegated Acts Under the Batteries Regulation

EBRA has been actively engaged with the European Commission on the technical aspects of several delegated acts under the Batteries Regulation. Key areas include:

• Recycling efficiency and material recovery calculations (already published)

• Carbon footprint calculation methodology (currently on hold by the Commission)

• Recycled content calculation rules (draft publication expected soon)

These delegated acts are highly significant for the battery recycling industry and will shape future reporting, compliance, and operational requirements across Europe.

6. Due Diligence (DD)

Within the Due Diligence discussions, two issues are of particular importance for EBRA members.

First, the mass balance allocation method appears to have been removed from the latest discussions, a point that has also been raised by Recharge.

Second, concerns remain regarding verification and traceability of data originating from outside Europe, particularly from China. Questions continue around ensuring a level playing field between recycling operations in Europe and Asia, especially concerning reporting standards, environmental compliance, and social responsibility.

Broader discussions within this working group also cover topics such as child labour, labour conditions, women’s rights, and environmental standards in global supply chains.

7. Available for Collection (AfC)

EBRA has submitted a position paper (members only) on the “Available for Collection” methodology.

Current discussions focus on:

• The methodology for calculating available battery volumes

• The number of years to consider after batteries are placed on the market

• Reporting complexity and data reliability

• The treatment of exported WEEE streams containing batteries

One recurring challenge is determining how batteries embedded in WEEE exported outside Europe should be accounted for within collection calculations.

8. Cobalt Exposure Limits

EBRA has also been involved in discussions with the Cobalt Institute regarding future occupational exposure limits for cobalt.

Together with the Cobalt Institute, EBRA has requested a five-year transition period to allow industry sufficient time to adapt to potential new exposure requirements.

9. Labelling of Batteries

Earlier this year, EBRA prepared a position paper (members only) on battery labelling requirements.

A central point raised by the association is that labelling on end-of-life batteries may have limited practical value, as labels are often damaged or destroyed during the product lifecycle and waste handling stages. Similar concerns apply to QR codes, particularly regarding long-term durability and readability after many years of use.

As implementation discussions continue, EBRA remains committed to ensuring that practical recycling realities are fully considered within future regulatory requirements.