Central Europe


The definitions and legislation for batteries in Germany are very similar to EU regulations. German legislation classifies Li-ion batteries as “other batteries” (16 06 05 of waste code), which are generally classified as non-hazardous [1]. In 2015, after strong criticism, the Committee for the Environment, Nature Conservation and Reactor Safety proposed an amendment to the legislation to treat Lithium-ion batteries as a separate type of battery [2]. Due to concerns about competitive disadvantage of German recyclers caused by stricter regulations, the German Federal Council (Bundesrat) did not adapt this change [2], [3].

Germany's Federal Council (Bundesrat) recommended an amendment to the classification, which was unsuccessful [4]. Nevertheless, the federal states of Germany have the right to tighten the national law inside their respective regions. Germany invests heavily in battery research, both with government incentives and private initiatives. In June of 2019, the national research center for battery production (Forschungsfertigung Batteriezelle) was created in Münster, receiving more than 200 M€ of government support [5]. Industrial efforts in the field of batteries are driven mainly by car manufacturers in cooperation with battery producers. These efforts include, inter alia, a 14 GWh battery pack factory in Erfurt by CATL (production planned to start in 2021), to supply BMW and VW; a 6-10 GWh factory from FARASIS, which will produce batteries for Daimler in Bitterfeld-Wolfen (production planned to start in 2022); and a joint venture between VW and Northvolt to build a 16 GWh plant in Salzgitter (production planned to start at the end of 2023). Furthermore, VW plans to integrate a battery recycling plant into the Salzgitter production site, with an initial capacity to recycle 3,000 batteries each year [6].

Recycling is an area of strong research In addition, R&D in Germany with initiatives is also focussing on battery recycling, such as the LithoRec project of TU Braunschweig. The collaboration between industry and university was funded by the German Federal Ministry of Environment and focuses on developing an environmentally friendly recycling technology for Li-ion EV batteries. The technology is being used by the battery recycling plant of the company Duesenfeld GmBh since 2017 [7] [8].



Poland implemented the EU directives without any major deviations. The most important regulation obstacle for the Li-ion battery collection and recycling is the lack of specific definition regarding this type of battery. The EoL Li-ion batteries are labeled as “other batteries” from industrial origin, making it difficult to distinguish the real amounts in the market. 

Poland has its own e-mobility directive that sets the goals for charging stations and electrification of public transport. The government sets the maximum purchase subsidy for personal EVs, trucks and buses at the level of 30% of the total price (there are also limits for the maximum price of the vehicles) [9]. So far, recycling is not incentivised, but rather regulated. Every company introducing products including Li-ion batteries is responsible for their collection and recycling. The company can outsource these activities to waste management companies.

Furthermore, Poland plays a very important role in the value chain of Li-ion batteries in Europe. Due to large investments from Asian companies (such as LG Chem), Poland has become the largest Li-ion battery exporter in the EU [10]. Such development can be explained, among other reasons, by: relatively cheap labour, strategic geographical location (automotive industry in Germany, access to the Baltic Sea), and incentives from the Polish government. Major manufacturing plants creating an interconnected supply chain for battery manufacturing are being developed in the lower Silesia region: cells (LG Chem [11]), separators (SK Innovation [12]), electrodes (Umicore [13]), cathode material (Johnson Matthey [14]), battery packs (Daimler [15]). Most of these investments are planned to be operational in the years 2020-2021. A second parallel supply chain is being developed by Swedish battery manufacturer Northvolt, which, in 2019, started establishing a battery pack assembly line in Gdynia [16]. The facility will be supplied by Northvolt cells coming from its manufacturing plant in Skellefteå (Sweden) and the packs will be mostly destined to EV manufacturers in Germany. 

Currently, Li-ion batteries cannot be recycled in Poland due to the lack of suitable facilities. There are several companies that recycle lead acid and nickel cadmium batteries, but the lithium-based batteries have to be sent to recycling facilities in Germany, France, Finland and China. Poland currently exceeds the EU requirements for waste battery collection: the rate was 82% in 2018 (the EU proposed a minimum of 45%). The main collection companies include: Reba, Remondis and Asekol.



The Austrian government closely follows the EU legislation. In contrast to Germany, Austria specifies Li-ion batteries as a separate battery type, and considers them a hazardous waste [17]. From the industry side, little information could be obtained. Varta AG, a company offering household batteries and whose founder, Adolph Müller, was Austrian, announced intentions to move into Li-ion batteries, but has not yet started the implementation phase. Moreover, it is not clear whether Varta AG will receive governmental support to kick start the project, while another obstacle may be a split shareholder opinion, as many criticize the high risks of large scale battery manufacturing and the capital intensiveness of production facilities [18].



Switzerland categorizes batteries as hazardous waste [19], and has thus developed strict regulations, all under the surveillance of the BAFU (the country’s federal environmental agency). The BAFU decides whether the export of batteries is allowed or not (based on the guarantee of environmental standards), while also setting the prices for recycling [19]. The high recycling prices, which are often criticized by battery companies, are usually justified by officials as a way to ensure a high quality of recycling.

Lithuania, Latvia, Estonia

The Baltic States do not currently play a significant role in the value chain of Li-ion batteries. As of this writing, there are no manufacturing or recycling facilities in Lithuania, Latvia and Estonia. These countries are believed to have a good innovation potential, hosting many startups that develop solutions for e-mobility, with Estonia being the leader. In 2011 Estonia introduced the national program ELMO for deployment of 165 EV charging stations network that still operate today. 

EoL Li-ion batteries collected in the Baltic States need to be exported to Western Europe (usually to Germany or France) or to Finland. One e-waste collector, BAO, reported problems with transportation of the batteries to Germany due to discrepancies in regulation. Companies introducing products containing Li-ion batteries to the market must pay a fee to one of the e-waste associations (e.g. Eesti Elektroonikaromu in Estonia), which then contract e-waste management companies to collect these batteries and send them to recycling. The management cost of EoL Li-ion batteries in Estonia is € 0,27/kg [20], and € 0,07/kg in Lithuania [21].


[1] Verordnung über das Europäische Abfallverzeichnis (Abfallverzeichnis-Verordnung - AVV). 2001.

[2] Bundesrat (German Federal Council), “Empfehlungen der Ausschüsse zu Punkt ‘Verordnung zur Umsetzung der novellierten abfallrechtlichen Gefährlichkeitskriterien’ der 936. Sitzung des Bundesrats am 25. September 2015,” 14-Sep-2015.

[3] “Änderung der AVV beschlossen,” 30-Sep-2015. [Online]. Available: https://www.gefahrgut.de/themen/abfaelle/aenderung-der-avv-beschlossen. [Accessed: 12-Feb-2020].

[4] N. U. R. U. W. Ausschuss für Umwelt, “340/1/15 Empfehlung des Budesrat zur Verordnung zur Umsetzung der novellierten abfallrechtlichen Gefährlichkeitskeitskriterien.” 14-Sep-2015.

[5] Government of the Federal State of North RhineWestphalia, “Press Release „Forschungsfertigung Batteriezelle“ kommt nach Nordrhein-Westfalen.” 27-Jun-2019.

[6] C. Randall, “VW releases battery recycling details - electrive.com,” electrive.com, 21-Feb-2019. [Online]. Available: https://www.electrive.com/2019/02/21/vw-releases-battery-recycling-details/. [Accessed: 31-Jan-2020].

[7] C. Hanisch, S. Olliges, and A.-C. Bartölke, “LithoRec – Recycling of Lithium Ion Batteries,” TU Braunschweig. [Online]. Available: https://www.ipat.tu-bs.de/en/forschung/elektrochemische-speichertechnik/lithorec-recycling-von-lithium-ionen-batterienlithorec. [Accessed: 11-Apr-2019].

[8] Duesenfeld GmBh, “Duesenfeld Li-Ion Battery Recycling.” [Online]. Available: https://www.duesenfeld.com/. [Accessed: 11-Apr-2019].

[9] “Nowe dopłaty do pojazdów elektrycznych! » GLOBEnergia,” GLOBEnergia, 26-Aug-2019. [Online]. Available: https://globenergia.pl/nowe-doplaty-do-pojazdow-elektrycznych/. [Accessed: 07-Nov-2019].

[10] “Poland exports the most lithium-ion batteries in EU.” [Online]. Available: https://wbj.pl/poland-exports-the-most-lithium-ion-batteries-in-eu/post/124154. [Accessed: 07-Nov-2019].

[11] “LG Chem is building a battery plant in Łódź, Poland,” THE ELEC, Korea Electronics Industry Media, 07-May-2019. [Online]. Available: http://en.thelec.kr/news/articleView.html?idxno=315. [Accessed: 07-Nov-2019].

[12] M. Kane, “SK Innovation To Build New Battery Separator Plant In Poland,” InsideEVs, 07-Apr-2019. [Online]. Available: https://insideevs.com/news/343706/sk-innovation-to-build-new-battery-separator-plant-in-poland/. [Accessed: 07-Nov-2019].

[13] C. Randall, “Umicore sets up cathode factory in Poland - electrive.com,” electrive.com, 02-Jun-2018. [Online]. Available: https://www.electrive.com/2018/06/02/umicore-sets-up-cathode-factory-in-poland/. [Accessed: 07-Nov-2019].

[14] C. Hampel, “Johnson Matthey to build cathode material plant in Poland - electrive.com,” electrive.com, 28-Mar-2019. [Online]. Available: https://www.electrive.com/2019/03/28/johnson-matthey-to-build-cathode-material-plant-in-poland/. [Accessed: 07-Nov-2019].

[15] M. Kane, “Mercedes-Benz Announces New Battery Factory In Poland,” InsideEVs, 22-Jan-2019. [Online]. Available: https://insideevs.com/news/342341/mercedes-benz-announces-new-battery-factory-in-poland/. [Accessed: 07-Nov-2019].

[16] A. Rosenfeld, “Northvolt closes funding round with $1 billion cash boost for northern Sweden hub,” The Local, 12-Jun-2019. [Online]. Available: https://www.thelocal.se/20190612/swedish-battery-company-northvolt-raises-1-billion-for-state-of-the-art-factory. [Accessed: 07-Nov-2019].

[17] Federal law of Austria: Abfallverzeichnisverordnung. 2003.

[18] Bundesamt für Umwelt (BAFU), “Abfallwegweiser Batterien,” “Bundesamt für Umwelt (BAFU),” 21-Jun-2019. [Online]. Available: https://www.bafu.admin.ch/bafu/de/home/themen/abfall/abfallwegweiser-a-z/batterien.html. [Accessed: 11-Apr-2019].

[19] B. F. U. Bafu, “Batterien,” bafu.ch, 21-Jun-2019. [Online]. Available: https://www.bafu.admin.ch/bafu/de/home/themen/abfall/abfallwegweiser-a-z/batterien.html. [Accessed: 04-Nov-2019].

[20] “Elektroonikaromu.” [Online]. Available: http://www.elektroonikaromu.ee/web/?cat_ID=13. [Accessed: 07-Nov-2019].

[21] “Įkainiai – EPA.” [Online]. Available: https://www.epa.lt/ikainiai/. [Accessed: 07-Nov-2019].

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