Recycling is no longer just an environmental obligation. It has become a geoeconomic imperative directly linked to Europe’s energy security and industrial competitiveness. The European Commission’s Critical Raw Materials Act reflects this change—it has set an ambitious target to source at least 25% of the EU’s annual consumption of strategic raw materials from recycling by 2030.

Europe, however, is making little progress. A recent European Court of Auditors’ report suggests that seven of 26 energy-transition-related minerals have recycling rates between 1% and 5% in the EU. This means, for example, that Europe is recovering just three tonnes from every 100 tonnes of natural graphite contained in batteries. According to the report, there are another ten minerals that Europe does not recycle at all, including lithium, gallium and silicon metal.

As such, recycling battery materials warrants far more attention. This valuable source of critical minerals could lower the continent’s dependence on Chinese mineral value chains; recycling battery materials is also much quicker than relying on the development of mines elsewhere that produce the same materials. However, fragmentation, red tape and unfavourable economics are hampering Europe’s recycling efforts, in part due to a regulatory framework that still treats battery materials as hazardous waste rather than a source of strategically important minerals.

Europeans need to focus on battery materials regulation with an industrial policy lens and pursue strategic partnerships with African countries to make gains in material recovery.

Using black mass and EVs

Recovered minerals from Europe’s waste—including end-of-life electric vehicle (EV) batteries, wind turbines, industrial parts and electrical wiring—are insufficient to meet all of Europe’s mineral needs. However, they can substitute for a share of primary minerals from mining, which would help Europeans derisk from Chinese mineral supply chains far quicker than new mines can come into production.

Europe will have relatively significant EV battery feedstock for recycling in coming years. Europeans were early adopters of EVs and European countries are global leaders in terms of EV sales as a share of total car sales: in Sweden, Denmark and the Netherlands, for example, EVs account for 58%, 56% and 48% of passenger-vehicle sales respectively, while fully electric vehicles comprise 22.6% of cars registered in the EU. High EV adoption means Europe should have a solid supply of EV battery feedstock for recycling facilities, provided it keeps this within the EU for recycling.

In March 2025, the EU re-classified “black mass” (the shredded EV battery waste processed to recover critical minerals) and end-of-life lithium-based, nickel-based and zinc-based batteries as “hazardous waste”. Black mass is important because it contains valuable critical minerals; if Europeans can process this within its borders, it can feed recovered minerals into European industry. This new classification prohibits export of black mass to non-OECD countries, while requiring that shipments within the EU and the OECD have prior notification and consent from the import, export and transit countries involved.

Europe currently exports around 80% of its black mass for refining elsewhere, mostly in Asia; South Korea’s OECD status and cheap recycling capacities make it a key destination, for example. The reclassification of black mass raises bureaucratic barriers to exporting out of the EU, contributing to efforts to prevent recycling feedstock leaking out. However, black mass is now more difficult to move within Europe, too, which makes aggregating feedstock for recycling within the EU a challenge. While Europe has some battery shredding (or pre-treatment) capacity to produce black mass, its refining capacity to recover minerals from black mass has lagged significantly.

Although forecasts suggest that Europe will slightly raise its material-recovery capacity in the coming years, it remains a minor player. China’s dominant share in global battery recycling capacity for the shredding and material recovery stages, which exceeded 80% in 2025, is set to continue.

Recent analysis estimates that the costs of hydrometallurgical recycling for nickel manganese cobalt (NMC) and lithium iron phosphate (LFP) batteries are respectively 70% and 67% higher in France than in China due to higher labour, energy, environmental compliance, dismantling and transport costs in Europe. China’s scale of feedstock—domestic supply of end-of-life batteries, scrap metal from the local automobile industry, and imported batteries and black mass—has further lowered their recycling costs.

Making battery recycling happen in Europe

The EU can take three clear steps to increase recycling black mass in Europe.

First, Europeans should implement stricter export restrictions on black mass and batteries to fully close off exports and retain the products for material recovery domestically.[1] The US took this position in July 2026, with President Donald Trump empowering federal officials to block exports of end-of-life batteries and electronic waste to contain these products for recycling within the US.

Second, Europeans need to urgently build more recycling capacity to refine black mass: Europe’s hydrometallurgical recycling capacity is less than 3,000 tonnes, which is around one-sixtieth of China’s. Estimates suggest that Europe needs the capacity to recycle 120,000–135,000 tonnes of black mass per year by 2030.

Third—and perhaps most challenging—Europeans need to ensure recycling in Europe becomes more economically viable. Failing this, tough export restrictions will lead to battery waste being stockpiled rather than recycled.

To achieve the above, Europeans need to develop new financing mechanisms—such as building recycling costs into the purchase price of products and using public finance to help offset recyclers’ higher costs in Europe—to make recycling more economically viable. This would be particularly timely as battery technology shifts from NMC to LFP batteries: since the latter are comprised of less valuable minerals, recyclers earn less from the sale of recovered minerals, necessitating support for project viability.

The provision of public finance, preferably at both the EU and member-state level, would help in the development of new technologies and processes that lower recycling costs by reducing energy requirements and improving recovery rates. Patent filings in battery recycling are growing significantly, with 2026 figures showing a 103% growth in filings (adjusted for lag). China leads in patent applications, although US and European companies—notably Belgium’s Umicore—are also active. To make Europe more globally competitive in recycling, Europe must increase its investments in innovation using public finance support.

Europeans also need to establish a strong domestic value chain. European battery recyclers, such as Germany’s Cylib and Tozero and Norway’s Hydrovolt, should identify and establish commercial agreements with EU-based offtakers for the minerals they recover—after all, if Europe has to export recovered minerals outside its borders for want of domestic offtakers, gains in recycling will be for nothing. Specifically, this requires European industry that uses recovered minerals (alongside primary source minerals from mining) to refine precursor cathode active material (pCAM) and cathode active material (CAM) stages for EV batteries.

Pursuing EU-Africa partnerships

Europeans should also look internationally to ensure recycling can feasibly reduce existing mineral supply chain dependencies. The EU needs to tap into other recycling feedstock markets and diversify its mineral supply chains by establishing recycling partnerships with OECD and non-OECD countries.

Indeed, the EU has explicitly included recycling within the remit of some strategic partnerships on critical minerals that it has signed with partner countries, including several African countries such as Namibia. By locating recycling and mineral-processing facilities in African countries, they can tackle the cost disadvantages Europeans face with regard to energy, land and labour costs on home soil. Namibia and Kenya are ideal partners: both have transport corridors and port infrastructure that make them well positioned to aggregate regional battery and electronic waste (e-waste); they can harness their abundant renewable energy resources can power material recovery facilities.

EU-Africa cooperation on recycling would also be advantageous to African countries. Joint operations create jobs, expand African mineral processing capabilities and link African mineral supply chains with European industry. Africa-based recycling facilities could also manage the growing quantity of end-of-life batteries and e-waste generated by African countries, notably from solar panels, energy-storage batteries and EV batteries from smaller two- and three-wheeler vehicles.

Sub-Saharan Africa’s projected growth in stationary storage capacity alone is significant: following current market trends, it will expand dramatically by 2030, with a storage capacity increase from 11 GWh to 83 GWh. If the region achieves universal access to electricity (SDG7), demand could more than double that, reaching a storage capacity of 190 GWh.

Europe’s road ahead

More recycling facilities are required to handle Africa’s growing volume of end-of-life battery feedstock. This presents an opportunity for growth both in Africa-based recycling, and in Africa-Europe recycling cooperation. However, this is not straightforward. Africa-Europe recycling partnerships need to invest in formalising supply chains for collection and storage; they need to build facilities for shredding batteries and e-waste; and they need to ensure that they can refine black mass to recover valuable materials. They would also need to develop the workforce skills and local-firm capabilities needed for efficient, environmentally-sound operations throughout the supply chain.

For African countries like Namibia and Kenya, such cooperation creates jobs and builds recycling capacity and expertise while integrating African mineral industrialisation into EU mineral supply chains. Recycling operations could also serve as anchor customers for increasing electricity generation and transmission investments in African countries, while local populations also benefit from improved electricity availability. Additionally, recycling in African countries helps address the continent’s growing e-waste management challenges.

For Europe, the increased recovery of critical minerals both domestically and through recycling partnerships with African countries offers greater supply chain diversification, access to minerals from non-OECD black mass and de-risking from Chinese mineral supply chains. All of this will happen faster than if Europeans continue to rely on global mine development. Europeans need to extend their strategic thinking beyond their borders, advancing recycling cooperation through critical minerals partnerships.

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[1] Interview with a representative of a mineral analytics company, February 19th, 2026.

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Many—perhaps most—Trump administration foreign policy initiatives find ways to make money for people selected by Trump officials. These deals unjustly enrich a chosen few.

They can also create facts on the ground that could bequeath problems to the next US administration. For example, grants of property rights to friends and family by the Trump-controlled Board of Peace could decide who has land and money in Gaza. This would limit the discretion of any approach that aims to increase Palestinians’ role in the place they live in. Other peace deals contain similar long tails.

To address this threat to peace around the world, the next US administration should introduce anti-corruption sanctions from its first day in office. The new administration could bar non-US persons or institutions involved in such transactions from the US itself and from the American financial system. To do this, the administration would use the Global Magnitsky Act and related executive orders, including the Trump-issued executive order 13818.

Europeans can help this along even now. They can begin to declare their expectations that a new US administration will break from the practice of enriching chosen insiders. Such statements will influence preparations for the new administration. Over the next two years, Europeans can also preserve information about US insider dealing while publicly refusing to support or finance such deals where European interests are involved, including in the south Caucasus, Western Balkans, Gaza, Russia and Ukraine. And they can shore up their own sanctions and anti-corruption regimes.

Starting discussions about sanctions now will also send a message about the importance of professional, thorough investigations by journalists, civil society, and especially by congressional committees if Democrats take control of the House or Senate. This information can inform decisions about sanctions. Clear signalling from American and European political leaders now may deter potential foreign partners of the current administration from entering into corrupt deals over the remaining two years of the administration.

What sanctions can and cannot do

Sanctions will not provide complete answers in any situation, and they may not be appropriate in some instances. An understanding of how they work will clarify their importance and some of their limitations.

Executive order 13818 authorises sanctions against any “foreign person” (that is, not a US citizen or person) who participated in:

corruption, including the misappropriation of state assets, the expropriation of private assets for personal gain, corruption related to government contracts or the extraction of natural resources, or bribery

The commercial aspects of President Donald Trump’s foreign policy appear to fall squarely into this framework. Even if not every instance is found to involve corruption, a close look is warranted. For example, Kazakh authorities were reportedly pressed to award a valuable mineral concession to a specific American company (associated with US political insiders, including the president’s family) while the administration considered financing for the development and export of the minerals. This was not an effort to promote a fair process in which American companies could compete—a staple of US government advocacy in any administration—but an attempt to short-circuit the normal process. It appears to involve the essence of the behaviour targeted by the Magnitsky act and executive order.

In Bosnia and Herzegovina, a specific American company was newly created by two US citizens with no relevant experience but with a track record of supporting the president (and one of whom is the brother of a senior official in the first Trump administration). The US lobbied for this company to receive a lucrative concession for a natural gas pipeline, and the US demanded the resignation of a reluctant international official.

American sanctions apply only to non-American citizens. It may seem unfair to leave US beneficiaries of a scheme out of a US response. But the administration’s power to require foreign persons or institutions to provide all relevant information about suspect transactions could impede the activities that unjustly enrich American insiders.

Further, by the end of the Trump administration, many insiders (and possibly some foreign persons) are likely to be covered by presidential pardons. This could make it difficult, if not impossible, to proceed with US criminal investigations, at least not without extensive litigation while the US justice system recovers from Trump’s attacks on its capacity. This could make a new administration look feckless, and foreign partners may expect that Trumpian practices will return in future administrations. Crucially, sanctions are not subject to the pardon power, and their emphasis on non-US persons and institutions will provide some protection against charges that they are part of a partisan agenda.

Another concern may be that sanctions have generally been adopted after careful review by relevant US agencies, including the Justice Department. Given the amount of information available, a reasonable basis for a decision on sanctions can be prepared for day one of a new administration. This decision can be accompanied by a provision that reviews will follow as new information becomes available and US government agencies rebuild enough capacity to conduct them.

The investigative resources of European governments, the US Congress (or parts controlled by Democrats after the 2026 midterms), civil society and independent journalism will provide an ample, well-documented basis for sanctions in many instances. By inviting those who might be subject to sanctions to provide information, the effort will gather more information, more quickly, aiding in decisions about priorities for further sanctions or investigations by congressional or law enforcement authorities.

Significantly, early sanctions may be necessary for a new administration to deliver on promises it makes on issues of foreign and domestic policy. For example, the Trump administration is seeking to have rights to minerals critical to US industrialisation granted to its preferred partners, including in Central Asia, Ukraine and eastern Congo. Individuals holding these rights would be important stakeholders in any policy shifts, even though they may have obtained the rights through insider dealing and could be opposed to the direction a new administration would like to take on policy.  

The leverage provided by a policy of using sanctions may be a key instrument of foreign policy

The same situation could occur in other locations. In addition to the examples of Gaza and the Western Balkans noted above, in Venezuela, if a democratic government emerges, it may face challenges from Trump-affiliated companies accustomed to working with Maduro-regime holdovers kept in place by Trump and Marco Rubio. Control of a key trade route from Central Asia to global markets, along with a US-taxpayer funded investment vehicle, is said to be in the process of being placed under the control of a Trump-associated individual. In each instance, more knowledge about what deals are in place and how they came to be will improve both policy and decisions on sanctions. The leverage provided by a policy of using sanctions may be a key instrument of foreign policy.

The list goes on. Even before his second inauguration, a Trump-owned business accepted a $500m investment from a fund controlled by a member of the United Arab Emirates’ ruling family; within weeks the UAE received an exemption to purchase high-end computer chips. A Chinese businessman purchased $50m in a Trump-owned crypto business (part of the president’s $1.2bn windfall from crypto in 2025); weeks later his US criminal problems were resolved by the president.

If other jurisdictions like the EU and Britain join new American sanctions efforts, the costs to the non-US individuals and institutions affected will be real. To do this, the EU might consider how its rule of law initiatives, including its investigative bodies such as OLAF or the European Public Prosecutor’s Office, could prepare to work alongside US sanctions authorities. It could propose that the EU and the US return to coordinating assistance programmes to reinforce public procurement reforms. Various European states have national anti-corruption sanctions programmes; more should consider adopting them.

Some will worry that rapid deployment of sanctions may distract from a new administration’s positive agenda. This will depend on the strength of that agenda. Europeans can help make clear that they regard this as a false choice: a break from the insider dealing of the Trump administration should be part of a new, positive plan for government. This will make it easier for a new administration to adopt sanctions policy as part of leaving Trump practices firmly in the past.

There will, of course, be difficult decisions around the application of sanctions. Not every example of insider dealing will be proven to be corrupt. Some potential targets of sanctions may be important to other US administration initiatives, and if the new administration defers sanctions it may be subject to accusations of hypocrisy. Other countries may object strongly to seeing their institutions or citizens named in sanctions documents. A new administration will face many choices like this; people who want to exercise power from Washington therefore need to prepare now and confront the choice early. It is better to start with a strong tool like sanctions rather than to disarm everywhere pre-emptively in order to avoid hard choices in a few places.

Wise observers of democratic transitions have said that democrats taking power after corrupt regimes should seek to be quick, effective and legal; but that they can be only two of the three. But sanctions might get a new administration closer to three out of three. They provide a legal tool that will help the next administration be quick and effective in stopping the insider enrichment typical of Trump foreign policy while coming with limits (no targeting of US citizens) and with the ability to adjust quickly. By taking up this tool, it will free itself of shackles that would come from those who seek to control the land and property important to peace in many parts of the world. But this will come to pass only if people begin to talk about it now. European leaders have the ability to help make sure that happens.

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