
European Economic Area
The European Commission’s update to the European List of Waste introduces new hazardous waste codes for battery-related waste, impacting manufacturers and recyclers. Effective from September 2026, these changes aim to enhance safety, traceability, and circular economy efforts. Companies must adjust waste handling processes to remain compliant with evolving EU regulations.
Published in March 2025. Dates, deadlines and stages may have changed since.
2 min readAI-drafted, expert reviewed

The European Commission has updated the European List of Waste (ELW), introducing new classifications for battery-related waste. Effective from September 2026, this amendment affects manufacturers, recyclers, and waste management firms across the EU value chain. The revised rules aim to enhance traceability, safety, and sustainability, ensuring hazardous materials are properly managed.
The amendment to Decision 2000/532/EC includes new waste codes for lithium-based, nickel-based, and sodium-based batteries, reflecting advances in battery chemistries and recycling processes. Among the key changes:
New hazardous waste classifications for intermediate battery waste fractions, including “black mass,” a material extracted from end-of-life batteries.Reclassification of alkaline batteries as hazardous waste due to updated scientific data on their composition.Enhanced traceability measures to improve sorting, recycling, and compliance with the EU’s Batteries Regulation (EU 2023/1542).
The new classifications will be mandatory from September 2026, allowing businesses 18 months to adapt. These changes are expected to tighten waste shipment regulations, requiring compliance with the Waste Framework Directive and Waste Shipment Regulation.
Manufacturers and recyclers must update waste handling processes, ensure proper classification of hazardous waste, and prepare for potential cost implications. The Circular Economy initiative remains central, with these updates promoting resource efficiency and safer recycling practices.
To stay compliant, affected companies should:
Audit current waste classifications to align with the new waste codes.Update waste management strategies to reflect the new hazardous waste requirements.Engage with regulatory bodies and industry groups for guidance on implementation.Invest in safer handling and recycling technologies to manage newly classified hazardous waste effectively.
Official source
ec.europa.euTopics
The update introduces new hazardous waste codes for lithium, nickel, and sodium-based batteries, reclassifies alkaline batteries as hazardous, and mandates stricter traceability and waste management rules. Compliance will be mandatory from September 2026, affecting manufacturers, recyclers, and waste handlers.
Companies must reclassify waste streams, implement new handling protocols, and comply with stricter hazardous waste regulations. This could increase costs but also drive investment in safer and more efficient recycling technologies, supporting the EU’s Circular Economy objectives.

Dr Steven Brennan
CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.
More from Dr Steven BrennanForesight follows changes like this one and shows where they reach your substances, products and markets.

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