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

Abstract

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.

EU battery policy targets downstream recycling, but the bottleneck is upstream design. Heterogeneous designs hinder high-value recycling. A strategy should promote design-for-disassembly, robotic hubs, and spent LIBs as strategic materials.

Broader context

The rapid growth of electric mobility and energy storage is dramatically increasing the number of spent lithium-ion batteries worldwide, making efficient recycling a critical component of a sustainable energy transition. While the European Union has introduced ambitious initiatives such as the Batteries Regulation and the Critical Raw Materials Act, the diversity of battery designs still represents a major obstacle to safe, automated, and economically viable recycling. This work highlights dismantling as a key bottleneck in the battery circular economy and argues for stronger policy measures, including mandatory design-for-disassembly and reinforced producer responsibility. By linking recycling policy to industrial strategy and resource security, the study contributes to broader debates on Europe's technological sovereignty and sustainable energy systems.

Introduction and context

The transition towards climate neutrality and electrified mobility is driving a rapid increase in demand for critical raw materials (CRMs) across Europe.¹ This trend is particularly evident in the automotive sector, where electric vehicles have recently outsold petrol vehicles for the first time in Europe.² CRMs, including for example lithium, cobalt, nickel, copper, graphite, rare earth elements, gallium, and germanium, are essential for batteries and other clean-energy technologies such as wind turbines, solar panels, hydrogen electrolysers, and electricity grids.^3,4 However, the supply of many of these materials remains highly concentrated in a limited number of countries. As shown in Table 1, battery-related CRMs are predominantly sourced from countries such as Australia, Brazil, China, the Democratic Republic of Congo, Indonesia, and South Africa.⁵ This concentration exposes supply chains to geopolitical tensions, price volatility, environmental pressures, and social risks.⁶

Table 1. Amount of CRM for batteries extracted from mines worldwide (and share of total production) in 2024, by largest producing country (in 1000 metric tons). Data from ref. 5.

	Cobalt	Natural graphite	Lithium	Nickel	Ferrosilicon and silicon metal
Australia	—	—	88 000 (36.7%)	—	—
Brazil	—	—	—	—	390 (4%)
Chile	—	—	49 000 (20.4%)	—	—
China	—	1 270 000 (79.4%)	41 000 (17.1%)	—	7400 (76.3%)
Democratic Republic of Congo	22 0000 (75.9%)	—	—	—	—
Indonesia	28 000 (9.7%)	—	—	2 200 000 (59.5%)	—
Madagascar	—	89 000 (5.6%)	—	—	—
Mozambique	—	75 000 (4.7%)	—	—	—
Philippines	—	—	—	330 000 (8.9%)	—
Russia	8700 (3%)	—	—	210 000 (5.7%)	520 (5.4%)
South Africa	—	—	—	—	—

In response to these challenges, the European Union has progressively strengthened its regulatory framework for battery sustainability and resource security. The Batteries Regulation 2023/1542 established the first lifecycle-based framework governing the sustainability, safety, and circularity of batteries placed on the EU market.⁷ The regulation introduced requirements for carbon footprint reporting, recycled content, supply-chain due diligence, digital battery passports, and Extended Producer Responsibility (EPR). Complementing this framework, the Critical Raw Materials Act (CRMA) aims to strengthen domestic sourcing, processing, and recycling capacities for strategic materials.⁸ More recently, RESourceEU was introduced to accelerate implementation through investment, permitting, procurement, and supply-chain diversification measures.⁹ In parallel, the proposed Advanced Materials Act (AMA) seeks to support innovation in advanced materials, resource efficiency, and circularity in future technologies. Taken together, these initiatives represent a substantial step towards a more resilient and circular European battery value chain. However, they remain focused predominantly on downstream outcomes, including recycling targets, recovery efficiencies, and supply security. Comparatively little attention has been devoted to the upstream design characteristics that determine whether dismantling and material recovery can be performed efficiently in practice. This omission is significant because the recyclability of lithium-ion batteries (LIBs) is strongly influenced by their design. Contemporary battery packs are primarily optimised for performance, safety, energy density, and manufacturing efficiency. As a result, they often incorporate complex architectures, irreversible joints, extensive use of adhesives, and highly heterogeneous configurations. These features increase dismantling complexity, limit the deployment of automation, and reduce the efficiency and quality of material recovery. Consequently, design choices made during battery development directly influence the technical and economic feasibility of recycling. This paper advances a central argument: the key limitation of current EU battery policy lies not in the absence of recycling targets, but in the insufficient regulation of upstream design features that ultimately determine whether recycling can be effectively implemented. By explicitly linking engineering constraints to policy design, this work addresses a gap that is often treated separately in the existing literature. The paper therefore examines how battery design affects dismantling and recycling performance and discusses policy measures capable of aligning technical feasibility with Europe's circularity, resource-security, and industrial-resilience objectives.

Methodological approach

This study adopts a structured narrative review approach, drawing on recent peer-reviewed literature across engineering, techno-economic, and policy domains related to LIBs recycling. The analysis combines evidence from academic studies, industrial case studies, and regulatory frameworks to examine current challenges associated with battery dismantling, design standardisation, automation, and recycling performance.

Particular attention is given to recent developments in automated disassembly, techno-economic assessments of recycling systems, and design-for-disassembly strategies. These studies were selected because they collectively address the relationship between battery design, dismantling feasibility, and material recovery outcomes, which forms the central focus of this paper. The reviewed literature consistently identifies dismantling as a key determinant of recycling performance. From a techno-economic perspective, dismantling costs and processing times vary substantially across battery designs, directly influencing the economic viability of recycling operations.¹⁰ From an engineering perspective, dismantling affects the accessibility and quality of material streams and therefore influences the feasibility of reuse, remanufacturing, direct recycling, and conventional recycling routes.¹¹ Dismantling performance depends not only on product design but also on labour requirements, infrastructure availability, safety constraints, and regulatory conditions.¹² Furthermore, design-for-disassembly studies show that improvements in dismantling performance may involve trade-offs with manufacturing complexity, resource use, and production costs.¹³ Taken together, the literature demonstrates that dismantling occupies a pivotal position between product design and recycling performance. Variations in dismantling time, cost, and accessibility affect plant throughput, automation potential, material contamination, and recovery efficiency. Design choices therefore determine dismantling feasibility, which in turn influences recycling performance and ultimately affects the practical achievability of policy objectives. The reviewed studies consistently highlight the strong influence of battery design on dismantling efficiency and demonstrate that high-value recycling pathways depend on the ability to selectively separate components and materials. Consequently, dismantling constraints should not be viewed solely as engineering challenges but also as systemic factors that directly influence the effectiveness of circular-economy policies and recycling regulations.

Technical constraints and regulatory gaps

The processing of end-of-life electric vehicle batteries involves a sequence of operations, including collection, sorting, dismantling, and material recovery, as illustrated in Fig. 1.¹⁴ Although the exact sequence depends on battery architecture, chemistry, and available equipment, dismantling represents the critical transition between battery use and material recovery. In this paper, dismantling refers specifically to the opening of battery packs and the removal of modules and components prior to downstream operations such as cell separation, shredding, sorting, and material recovery.

Fig. 1. Schematic overview of the main stages in the current processing of end-of-life (EoL) electric vehicle batteries. Within this sequence, “dismantling” refers specifically to steps (c) and (d), which involve the mechanical opening of the battery pack and the disassembly of modules and components. Step (e), “separation of individual cells”, may involve either non-destructive extraction or may be bypassed in favour of comminution processes. Comminution (e.g. shredding or crushing) and subsequent sorting are distinct downstream operations aimed at material separation rather than component recovery.

Different pre-processing routes can be adopted depending on the intended recycling strategy. Current industrial practice frequently relies on limited dismantling followed by shredding, as this approach is robust and adaptable to the wide variety of battery designs currently on the market. However, the choice of pre-processing route has important implications for recycling outcomes. Shredding generates mixed material streams containing active materials, current collectors, electrolytes, and structural components, reducing material purity and limiting the recovery of high-value fractions.¹⁵ While this approach is effective for large-scale processing, it sacrifices structural information and creates contamination that can constrain more advanced recovery pathways.

This limitation becomes particularly relevant in the context of direct recycling and cathode regeneration. Unlike conventional recycling routes that aim to recover elemental constituents, these approaches seek to preserve the morphology, crystallinity, and electrochemical functionality of active materials.¹⁶ Maintaining this embedded value can reduce processing requirements and improve overall resource efficiency. However, such approaches require selective separation of components and low contamination. From an engineering perspective, direct recycling is therefore only feasible when dismantling enables controlled and non-destructive separation of battery components before comminution takes place.

The feasibility of dismantling itself is strongly influenced by battery design. Manufacturers employ different cell formats, module architectures, cooling systems, fastening strategies, and internal layouts, resulting in highly heterogeneous battery packs.^17,18 This variability affects dismantling operations by increasing differences in cycle times, tool requirements, accessibility of components, and safety conditions. Opening a battery pack may require the removal of bolts, rivets, adhesives, welded joints, wiring harnesses, battery management systems, cooling components, and electrical interconnections.¹⁹ Adhesive bonding and welded joints are particularly problematic because they prevent non-destructive separation and often require force-intensive or destructive removal methods.

These design characteristics also limit the deployment of automation. Variations in battery geometry, fastener positioning, accessibility, and joint behaviour increase the complexity of robotic operations and require adaptive control strategies, reducing process predictability and throughput. As a result, dismantling remains labour-intensive, difficult to standardise, and challenging to scale. This issue is particularly significant because automation is frequently presented as a solution for future battery recycling systems, yet its effectiveness depends heavily on the degree of design standardisation and accessibility of battery components.

Safety introduces an additional layer of complexity. LIBs operate at high voltages, contain flammable electrolytes, and may undergo thermal runaway if damaged or improperly handled.^20,21 Dismantling therefore requires specialised equipment, controlled operating conditions, and stringent safety procedures, all of which increase operational costs and system complexity. Manual dismantling exposes workers to electrical, chemical, and mechanical hazards, while the variability of battery designs complicates the deployment of fully automated solutions.²² These safety considerations become increasingly important as the volume and size of end-of-life batteries continue to increase.

The combined effect of these factors extends beyond dismantling itself and directly influences recycling performance. Difficult dismantling increases processing costs, limits automation potential, and reduces the ability to selectively separate materials. Consequently, it affects the feasibility of advanced recycling routes, the quality of recovered fractions, and the overall economics of recycling operations.

Despite significant progress in European battery legislation, current regulatory frameworks remain focused primarily on downstream outcomes such as recycling targets, recovery rates, and environmental performance indicators. While these measures are important, they do not sufficiently address the upstream design characteristics that determine whether dismantling and high-quality recycling can be achieved efficiently in practice. Existing regulations do not impose binding requirements on key design features such as joint reversibility, component accessibility, modularity, or automation compatibility. Manufacturers therefore continue to optimise battery systems primarily for performance, safety, energy density, durability, and manufacturing efficiency, without systematically accounting for end-of-life processing requirements.

Additional limitations arise from the regulatory treatment of end-of-life batteries. Although the current framework appropriately recognises the safety risks associated with battery handling, its implementation can create logistical and administrative barriers that increase costs and complicate the development of decentralised recycling infrastructures. Similarly, while existing producer-responsibility mechanisms assign responsibility for end-of-life management, they provide only limited incentives for improving dismantling performance through product design.

Taken together, these technical and regulatory constraints reveal a fundamental mismatch between recycling objectives and the conditions required to achieve them. The factors that most strongly influence dismantling feasibility originate at the design stage, yet current policy instruments focus predominantly on outcomes occurring after batteries reach the end of their service life. As a result, the effectiveness of recycling systems depends not only on downstream recovery technologies but also on the upstream design choices that determine whether batteries can be dismantled efficiently, safely, and at scale.

Discussion

Dismantling is widely recognised as one of the most complex, hazardous, and consequential stages of the LIBs recycling chain. The evidence reviewed in this work suggests that dismantling performance is not simply an operational issue but a key determinant of recycling efficiency, economic viability, and material recovery quality.²³ In this sense, dismantling defines the practical conditions under which recycling targets, circularity objectives, and resource-security ambitions can be achieved. The economic consequences of design variability become evident when dismantling performance is quantified. Disassembly times range from tens of seconds to several minutes depending on battery architecture and disassembly depth.¹³ A comparative techno-economic assessment of six commercial EV battery packs reported dismantling costs ranging from USD 47.41 to USD 194.11 per pack, with differences of up to 75% primarily driven by the number of modules and fasteners.¹⁷ The same study estimated that full automation could increase dismantling capacity by up to 600% and generate annual savings of up to USD 190 million by 2040. These findings demonstrate that battery design has a direct and measurable influence on the economics of end-of-life processing.

Recent reviews of LIBs recycling economics further highlight the importance of upstream process stages in determining overall recycling viability.²⁴ Although reported profit margins vary substantially across pyrometallurgical, hydrometallurgical, and direct recycling routes, many economic models omit critical cost components such as transport, dismantling, and capital expenditure. Consequently, recycling costs may be systematically underestimated and comparisons between recycling technologies can become misleading. These findings reinforce the need to consider dismantling and preprocessing not as isolated operations, but as integral determinants of recycling economics and overall system performance. Additional evidence indicates that bypassing dismantling is not necessarily the most cost-effective strategy. Integrating dismantling before recycling can reduce overall processing costs by up to 80% compared with routes that rely on early-stage shredding.²⁵ Prior separation of components reduces downstream processing requirements, improves material sorting, and increases the quality of recovered fractions. Similar conclusions emerge from recent robotic disassembly studies. Experimental module-to-cell disassembly systems have demonstrated reductions in processing time from approximately 601 s under manual operation to 224 s under robotic operation, corresponding to a productivity increase of almost 170%, while maintaining projected payback periods close to one year.²⁵ These results indicate that automated dismantling is becoming increasingly feasible from both technical and economic perspectives. However, the deployment of automation remains constrained by the diversity of battery designs currently available on the market. Differences in cell formats, module arrangements, cooling systems, fastening strategies, and internal layouts create highly heterogeneous products that require different dismantling procedures.^26,27 Even relatively small design variations can significantly affect accessibility, tooling requirements, operation time, and safety conditions. As a consequence, dismantling remains difficult to standardise and automated systems must cope with high variability compared with conventional industrial automation environments. The implications extend beyond dismantling itself and directly influence material recovery outcomes. Current industrial practice often addresses design diversity through shredding, which generates a dimensionally uniform waste stream suitable for large-scale processing. While effective from a throughput perspective, shredding also creates chemically heterogeneous fractions containing mixtures of active materials, current collectors, electrolytes, and structural components.²⁸ The resulting contamination reduces material purity and limits the recovery of high-value fractions. In addition to cathode materials, copper contained in current collectors and electrical connections represents a major source of recoverable value, and its efficient separation is essential for both economic and environmental performance. This issue becomes particularly important in the context of advanced recycling routes. Direct recycling and cathode regeneration seek to preserve the morphology, crystallinity, and electrochemical functionality of active materials rather than recovering only their constituent elements.^16,29 The relationship between upstream design decisions, dismantling performance, material recovery quality, and broader strategic outcomes is summarised in Fig. 2. The figure illustrates how design-for-disassembly measures and improved information availability can reduce contamination, facilitate advanced recycling pathways, and ultimately contribute to resource security and industrial resilience. These approaches can retain a larger proportion of the value embedded during battery manufacturing, reducing both energy demand and material losses. However, they are highly sensitive to contamination and depend on selective pre-processing. Design-for-disassembly therefore emerges as a critical enabling factor, since controlled separation of battery components can preserve material integrity, whereas shredding-based approaches often destroy structural information and lock the system into lower-value recovery routes. The widespread use of adhesive bonding and welded joints further illustrates the tension between manufacturing optimisation and end-of-life recovery. These joining techniques improve structural integrity, reduce weight, and facilitate high-speed assembly, but simultaneously hinder dismantling and prevent non-destructive recovery of modules and cells. More broadly, battery architectures reflect legitimate engineering trade-offs among energy density, safety, thermal management, mechanical stability, manufacturability, and cost.²⁷ Consequently, standardisation should not be interpreted as a call for complete design uniformity. Excessively prescriptive requirements could constrain design flexibility, slow the adoption of emerging chemistries such as solid-state batteries, and impose unnecessary redesign costs on manufacturers. The challenge is therefore to identify those design features that have the greatest influence on dismantling performance, such as joint reversibility, accessibility, and information transparency, while preserving room for technological innovation. Safety considerations reinforce the importance of these design choices. LIBs operate at high voltages, contain flammable electrolytes, and may enter thermal runaway if subjected to mechanical, thermal, or electrical abuse.^20,21 Manual dismantling exposes workers to electrical hazards, toxic vapours, unstable cells of uncertain state of health, and mechanical risks associated with inaccessible or damaged components. Although automation can reduce worker exposure to these hazards, the diversity of battery architectures continues to limit the widespread deployment of robotic solutions.²² Furthermore, current guidance on dismantling risk assessment remains fragmented and is not yet consistently implemented across industrial facilities.³⁰ Taken together, these findings highlight that dismantling performance is shaped by decisions made long before batteries reach the end of their service life. Design choices influence processing costs, automation feasibility, safety conditions, material recovery quality, and the viability of advanced recycling pathways. Consequently, the effectiveness of recycling systems cannot be understood solely in terms of downstream recovery technologies. It is equally dependent on the upstream design characteristics that determine whether batteries can be dismantled efficiently and safely in the first place. Finally, battery recycling should be considered within a broader strategy of industrial resilience and resource security. Supply chains for lithium, cobalt, nickel, graphite, and other battery-critical materials remain highly concentrated outside Europe and are increasingly exposed to geopolitical risks. As electric vehicle deployment accelerates, recovered materials are likely to become an increasingly important source of supply. High-quality recycling therefore represents not only an environmental necessity but also a strategic capability that can strengthen European industrial competitiveness and reduce dependence on vulnerable external supply chains.

Fig. 2. Conceptual framework linking upstream battery design and policy interventions to downstream recycling performance and strategic outcomes. Design-for-disassembly principles and digital battery passports enable safer and more efficient automated dismantling, reducing variability and material contamination. This leads to cleaner material streams, enabling higher-value recycling pathways such as direct recycling and regeneration. The resulting improvements in material recovery and circularity contribute to EU resource security and industrial resilience. This figure was realised with Biorender.

Conclusion and policy implications

The coming decade will bring an unprecedented increase in end-of-life LIBs across Europe. These batteries contain substantial quantities of CRMs that are essential not only for the energy transition but also for the long-term resilience of European industry. The analysis presented in this paper demonstrates that Europe's capacity to recover these materials is constrained by a structural weakness that remains insufficiently addressed in current policy frameworks: the disconnect between battery design and end-of-life processing. The evidence reviewed throughout this work shows that dismantling performance is strongly influenced by battery architecture, joining technologies, accessibility of components, and the degree of design standardisation. These design choices determine dismantling costs, automation feasibility, safety requirements, and material recovery quality. Consequently, they also influence the practical achievability of recycling targets. As long as upstream design remains largely unconstrained, downstream recycling objectives will remain difficult—and in some cases impossible, to achieve efficiently. Table 2 synthesises the principal technical, regulatory, and infrastructural barriers limiting high-value LIB recovery and links them to the policy interventions proposed in this work. It provides a structured overview of how upstream design choices, regulatory conditions, and infrastructure constraints jointly affect dismantling feasibility and recycling performance. Together, they indicate that improving recycling performance requires a broader policy perspective that addresses not only recovery outcomes but also the design conditions that shape end-of-life processing. A first priority should be the progressive introduction of design-for-disassembly requirements. These should focus on the design features that most strongly influence dismantling efficiency, including joint reversibility, component accessibility, standardised interfaces, and the availability of structured design information. Such measures would facilitate automation, reduce safety risks, and improve material recovery while still allowing flexibility for innovation in battery chemistry and system integration. A second priority concerns the evolution of producer responsibility frameworks. While EPR has played an important role in assigning responsibility for end-of-life management, it provides only limited incentives for improving dismantling performance through product design. Alternative approaches, including more individualised forms of producer responsibility, could strengthen the connection between design decisions and end-of-life outcomes by encouraging manufacturers to directly account for the recyclability of their products.³¹ A third area for reform concerns the treatment of spent batteries within regulatory frameworks. While the classification of end-of-life batteries as hazardous waste remains essential from a safety perspective, a complementary recognition of their role as strategic secondary raw materials would better reflect their economic and strategic value. Such an approach could facilitate material flows, reduce unnecessary administrative burdens, and support the development of regional recycling ecosystems without compromising safety requirements.

Table 2. Structural barriers to LIB recovery that are not considered in the available EU policy measures, including a qualitative assessment of relative importance, expected impact, and level of supporting evidence. The table integrates technical, regulatory, and system-level constraints identified in the literature, highlighting how upstream design features, regulatory frameworks, and infrastructure limitations jointly influence dismantling feasibility and recycling performance. The qualitative indicators are derived from techno-economic analyses, experimental studies, and policy-oriented research and are intended to provide a structured basis for prioritising policy interventions.

Barrier/problem	Technical/regulatory manifestation	Impact on recycling and circularity	Recommended EU policy measure	Relative importance	Expected impact	Level of evidence
Design heterogeneity	Multiple pack architectures, diverse fasteners, adhesives, non-standard layouts	Slow, costly, and unsafe dismantling; limits automation and reduces recovery efficiency	Mandatory EU-wide design-for-disassembly standards (reversible joints, standardised interfaces, improved accessibility)	High	High impact	Strong (techno-economic analyses + experimental studies)
Hazardous-waste classification of LIBs	Strict handling, storage, and cross-border transport requirements	Increased logistics cost, slow processing, and barriers to decentralised recycling	Reclassify spent LIBs also as strategic secondary raw materials while maintaining safety requirements	High	High impact	Moderate (policy + system-level studies)
EPR liability until ‘end-of-waste’	Producers retain responsibility until final treatment	Limits new recycling actors, discourages local dismantling, increases transport	Reform EPR to enable earlier transfer of responsibility and decentralised recycling systems	Medium–high	High impact	Moderate (policy and circular economy studies)
Insufficient dismantling infrastructure	Lack of investment in robotics, fire-safe systems, and diagnostics, especially for SMEs	Limited automation, slow scaling, higher operational risks	EU-supported regional robotised dismantling hubs and shared infrastructure	High	High impact	Moderate–strong (techno-economic + system studies)
Regulatory complexity and permitting delays	Lengthy approval processes for recycling facilities	Delayed deployment of recycling capacity and loss of recoverable materials	Streamlined permitting and regulatory sandboxes under the AMA	Medium	Moderate impact	Moderate (policy analyses)
Under-recognition of LIB waste as resource for advanced materials	Recovered materials not integrated into advanced materials value chains	Missed opportunity for circular innovation and material valorisation	Integrate LIBs-derived materials into AMA strategic projects and R&I pipelines	Medium	Moderate impact	Emerging (innovation and policy literature)
Lack of standardised data and design information	Limited availability of structured information on battery composition and architecture	Inefficient sorting, safety risks, and limited automation potential	Full implementation and standardisation of digital battery passport systems	High	High impact (enabling condition)	Strong (digitalisation and automation studies)

Infrastructure development also represents a critical requirement. The deployment of automated dismantling systems requires substantial investments in robotics, diagnostics, fire-safe facilities, monitoring systems, and specialised expertise. Many small and medium-sized enterprises currently active in battery recycling lack the capacity to make such investments independently. Publicly supported regional dismantling hubs could therefore provide shared access to advanced infrastructure, improve safety conditions, and accelerate the scaling of automated recycling systems. The digital battery passport can play an important enabling role in this transition. By providing standardised and machine-readable information on battery composition, architecture, joints, and dismantling procedures, it can improve traceability, facilitate automated dismantling, and support more efficient sorting and processing operations. More broadly, digitalisation offers opportunities to integrate battery management, diagnostics, material tracking, and end-of-life processing within a more comprehensive circular-economy framework.³² Implementation of these measures is likely to require a phased approach. In the short term, efforts should focus on improving transparency and data availability through battery passports and harmonised reporting requirements. In the medium term, design-for-disassembly guidelines and certification schemes could be introduced to encourage gradual alignment of battery designs with end-of-life requirements. In the longer term, mandatory design standards, harmonised interfaces, and large-scale automated dismantling infrastructure could provide the foundation for a mature circular battery economy. These developments should also be considered within the broader context of European industrial strategy. The forthcoming AMA provides an opportunity to strengthen the integration of recycling within future materials innovation policies. Recovered lithium, cobalt, nickel, copper, graphite, and other battery materials should be recognised not only as inputs for battery production but also as strategic resources for future advanced-materials value chains. In this sense, recycling is not merely a waste-management activity but an enabling technology for future industrial development. Europe therefore stands at a pivotal moment. Batteries are no longer simply products that require environmental management at the end of their lives; they are strategic assets embedded within a broader system of resource security, industrial competitiveness, and technological sovereignty. A policy framework that aligns battery design, dismantling processes, recycling technologies, and materials innovation can transform end-of-life batteries from a waste-management challenge into a cornerstone of European circular manufacturing. Ultimately, LIB recycling should be understood not only as an environmental obligation but also as a strategic industrial capability. Without addressing the upstream design constraints that shape dismantling performance, downstream recycling targets risk remaining formally ambitious but practically unattainable. Conversely, by integrating design-for-disassembly, digitalisation, targeted regulatory reform, and infrastructure investment into a coherent policy framework, Europe can establish a closed-loop battery ecosystem capable of supporting both its climate ambitions and its long-term material security.

Author contributions

Alessandra Zanoletti: data curation, formal analysis, investigation, visualization, writing – review and editing. Alberto Mannu: data curation, formal analysis, investigation, visualization, writing – review and editing. Gavin Harper: investigation, visualization, writing – review and editing. Elza Bontempi: conceptualization, funding acquisition, investigation, methodology, project administration, resources, supervision, validation, visualization, writing – original draft.

Conflicts of interest

There are no conflicts to declare.

Data availability

No primary research results, software or code have been included and no new data were generated or analysed as part of this article.