Towards a courageous EU policy for recycling spent lithium-ion batteries: rethinking dismantling, standardization, and responsibility

The rapid expansion of electric mobility across Europe is generating, and is expected to generate, unprecedented volumes of end-of-life lithium-ion batteries (LIBs), exposing structural weaknesses in the European Union's regulatory and industrial framework for battery recycling. We have crossed the point at which electric vehicles, for the first time, have out-sold petrol vehicles in Europe. Recent EU initiatives, including the Batteries Regulation, introduce significant advances, including carbon footprint reporting, mandatory recycled content, digital battery passports, sustainability and circularity requirements, and stronger extended producer responsibility. The heterogeneity of battery designs is widely recognized as a key constraint affecting dismantling efficiency, automation feasibility, and material recovery outcomes. These design issues directly impede automation, depress material recovery yields, and undermine the EU's circular economy and industrial sovereignty objectives. Drawing on assertive industrial policies, this paper argues that the EU should adopt a bolder stance. It proposes the introduction of harmonised design-for-disassembly requirements for all batteries placed on the EU internal market, alongside a reform of Extended Producer Responsibility and waste classification to recognise spent batteries as strategic secondary raw materials. It also calls for the development of publicly supported robotised dismantling hubs. The paper argues that the main limitation of current EU battery policy lies not only in downstream recycling performance, but more fundamentally in the absence of binding upstream design requirements that determine whether dismantling, and therefore high-quality recycling, can be technically and economically achieved.