Policy implications

The planned actions of the LIFE DRONE project will contribute to the implementation of the following EU directives:

  • Directive 2006/66/EC on batteries and accumulators – It fixes a mandatory 45% batteries collection rate and 50% recycling efficiency for Li-ion batteries. The proposed process increases the recovery of Ni, Mn and Co by 60 kg/ton of batteries, thus contributing to the recycling efficiency objective. Further, the project contributes to the collection objective by increasing the income from Li-ion batteries recycle, which can sustain new collection programs.
  • Directive 2008/98/EC – It states that the waste policy should privilege the following order of actions (waste hierarchy): prevention, re-use, recycling, and other recovery. The project reduces the waste fraction destined to landfilling or incineration by increasing the recycling efficiency of Li-ion batteries. In addition, the project will demonstrate the possibility to recover from EoL Li-Ion batteries and re-use the graphite, which is a critical raw material, thus moving one step ahead the proposed process in the waste hierarchy.
  • Directive 1999/31/EC (Waste Landfill Directive): the implementation of this directive in DRONE will be ensured by the reduction of the unrecovered waste fraction destined to landfill.
  • Directive 2008/1/EC (Integrated Pollution Prevention Control) (IPPC): The proposed process will reduce the environmental impact associated to the recycle of primary lithium batteries compared to conventional pyrometallurgical processes thereby contributing to implement this directive.

EU Batteries Regulation 2023: The EU Batteries Regulation 2023 that strengthens sustainability rules for batteries and waste batteries came into force on 17 August 2023 (the Regulation). The Regulation regulates the entire life-cycle of batteries, including reuse and recycling, and ensures that the industry takes steps to reduce the adverse environmental and human health impacts associated with production and disposal. The Regulation imposes significant additional obligations and responsibilities on various economic operators, particularly in respect of conformity assessments, product labelling and extended producer responsibility requirements.

1. Conformity assessments and general labelling requirements: From August 2024, manufacturers will be required to carry out a conformity assessment procedure on any battery it intends to place on the market or put into service. Once compliance has been demonstrated, manufacturers must then affix the CE mark to the battery. The Regulation also provides for extended general labelling and information requirements. All batteries will have to bear the information set out under Part A of Annex VI, which goes significantly beyond the current information obligations. This requirement will come into force no earlier than August 2026.

2. Battery Passport : Eventually, LMT batteries (those used for light means of transport, such as an electric bike or scooter), industrial batteries with a capacity of more than 2kWh, and electric vehicle (EV) batteries will additionally require an electronic record (to be known as a battery passport). The battery passport that must contain various information relating to the battery as set out in Annex XIII of the Regulation (such as the material composition of the battery and information on the battery’s carbon footprint). The battery passport shall be accessible through a QR code.

3. Performance, durability and sustainability requirements for specific batteries: All EV batteries, rechargeable industrial batteries with a capacity of more than 2kWh and LMT batteries, must be accompanied by a carbon footprint declaration for each battery model per manufacturing plant. The declaration must contain information regarding the battery model, the carbon footprint of the battery, and information regarding the carbon footprint of the battery differentiated according to its life-cycle stage. Eventually, this information shall also be provided via a QR code but initially it must be in hard copy and accompany the battery. These obligations will be introduced between February 2025 and 2030 depending on the type of battery.

Additionally, such batteries will also eventually have to be accompanied by a document containing values for the electrochemical performance and durability parameters as set out at Annex IV of the Regulation.

For industrial batteries, EV batteries, LMT batteries, and SLI batteries (those used for starting, lighting and ignition), containing cobalt, lead, lithium or nickel in active materials, the Regulation stipulates certain minimum thresholds for recycled content. Further, there is  a requirement for accompanying documentation to set out the percentage share of such recycled content.

4. Performance and durability requirements for portable batteries of general use, removability and replaceability requirements: Portable batteries of general use, excluding button cells, will be required to meet minimum values for performance and durability. The relevant minimum requirements are set out in Annex III of the Regulation and can be amended by the European Commission. This is designed to reduce the environmental impact of portable batteries by increasing their efficiency.

The Regulation also addresses the removability and replaceability of batteries on consumer goods, and places obligations on the manufacturers of products incorporating portable batteries. By February 2027, those producers must ensure that batteries are readily removable and replaceable by the end-user at any time during the lifetime of the product. For LMT batteries, producers must ensure that those batteries, as well as individual battery cells included in the battery pack, are readily removable and replaceable by an independent professional at any time during the lifetime of the product.

By the end of 2030, the European Commission must also have assessed the feasibility of phasing out non-rechargeable portable batteries of general use.


5. Due-diligence requirements : From August 2025, all economic operators with a turnover of €40million or more placing new batteries on the EU market will be required to comply with due diligence obligations. This includes having an independently verified due diligence policy concerning the social and environmental risks of specific raw materials and ensuring its supply chain is both transparent and traceable.

The policy must also set out due diligence systems and procedures to deal with the supply of cobalt, natural graphite, lithium and nickel and be consistent with existing international standards.


6. Collection of waste portable batteries: Producers of portable batteries (or appointed producer responsibility organisations) will be responsible for ensuring the collection of all waste portable batteries. This will include establishing a take-back and collection system with collection points, the transportation of waste batteries to a waste treatment facility, and ensuring they are treated in accordance with the Regulation at that facility.


The Regulation sets out specific target collection rates as follows:

- 45% by 31 December 2023

- 63% by 31 December 2027; and

- 73% by 31 December 2030.

There are similar obligations regarding collection for waste LMT, industrial, EV, and SLI batteries. To monitor compliance of producers with the requirements as to the management of waste batteries, the Regulation obliges the Member States to establish a register of producers.

In addition, producers must meet these mandatory minimum levels of recycled content for industrial batteries, SLI batteries, and EV batteries:

16 percent for cobalt 

85 percent for lead

6 percent for both lithium and nickel

To demonstrate compliance with these new EPR regulations, manufacturers will need to include recycled content documentation for each battery they produce.