Notes from the desk.
Practical analysis on battery EPR, black mass, the battery passport and documented trading — written by the people who move the material, not observers of it.
UK batteries EPR reform: what's changing, and how to prepare.
A trading desk's view of where UK batteries EPR reform is heading β and how producers, schemes and recyclers should prepare.
Read the article Trading & complianceBlack mass: classification, TFS and why the codes matter.
How classification, EWC codes and the TFS regime determine where it can lawfully go.
Read the article Digital productsBattery passport readiness: a 2027 checklist for OEMs and recyclers.
A practical readiness checklist for OEMs and recyclers.
Read the article Worked exampleAnatomy of a documented trade: from enquiry to settlement.
A step-by-step worked example of how a mixed lithium-ion consignment moves from first enquiry to assay-based settlement β with the evidence trail it generates along the way.
Read the articleA standing note on scope. Insights are general commentary from a trading desk, not legal or regulatory advice. Verify requirements against the applicable legislation before acting on them.
The regulatory clock, as we track it.
The EU Battery Regulation phases in year by year, and national transpositions move at different speeds. This is the clock our compliance team plans against β reviewed as the regulation and its secondary acts develop.
Regulation (EU) 2023/1542 in force
The Batteries Directive is gone; a lifecycle framework covering production, use and end of life now applies.
Carbon-footprint declarations β clock not yet started
Originally slated for Feb 2025 for EV batteries, the methodology delegated act is delayed; declarations apply 12 months after it enters into force. The data has to be built now regardless.
EPR obligations apply across member states
Producer registration and financing of collection are live compliance questions in every EU market. (Supply-chain due diligence, originally here, was postponed β see Aug 2027.)
Minimum recycling efficiencies bind recyclers
Broadly 65% for lithium-based batteries, 75% lead-acid, 80% nickel-cadmium, 50% others β by weight.
Digital battery passport becomes mandatory
EV, LMT and industrial batteries above 2 kWh placed on the EU market must carry a passport, accessible via QR code. Seven months of runway from today's date is less than one product cycle.
Supply-chain due diligence applies
Postponed two years by the 2025 Omnibus (Regulation (EU) 2025/1561): responsible-sourcing duties for cobalt, natural graphite, lithium and nickel apply from 18 August 2027.
Collection at 63% Β· recovery targets bite
Portable collection target rises to 63%; recovered-material targets apply β broadly 90% cobalt, copper, lead and nickel, 50% lithium.
LMT batteries get their own 51% collection target
The e-bike and e-scooter streams growing fastest in the waste system get a dedicated obligation.
Efficiency and recovery ratchet up
Recycling efficiency 70% for lithium-based and 80% for lead-acid, and portable collection 73% (end-2030); LMT collection 61% and recovery at 95% / 80% for lithium (end-2031).
Recycled content becomes a bill-of-materials line
New industrial, EV and SLI batteries must declare minimum recycled content β broadly 16% cobalt, 85% lead, 6% lithium, 6% nickel, rising again from 2036.
Headline milestones under Regulation (EU) 2023/1542, summarised as planning context β not legal advice. Dates and thresholds are subject to secondary legislation and national implementation. Last reviewed July 2026.