Mining, recycling and trust. Chances and challenges for a resilient EU Battery supply chain

This report assesses how the EU can secure critical raw materials for battery electric vehicle and battery stationary storage through a combined strategy of mining, recycling, and social license to operate (SLO), while remaining aligned with environmental and social safeguards.

The report argues that EU raw materials policy remains overly extractioncentric, as reflected in CRMA strategic project selection (15 extraction vs. only 7 recycling projects), despite clear environmental and strategic advantages of recycling and circular economy measures. It recommends:

• Rebalancing financial and regulatory support in line with a mitigation hierarchy of avoid, repurpose, reuse, repair, remanufacturing, recycle and second
  life applications.
• Reforming and strengthening EU legislation, including updating the Mining Waste Directive, ensuring CRMA strategic status cannot override core environmental directives, and resisting dilution of corporate due diligence frameworks.
• Embedding SLO from project inception via mandatory SIA, meaningful civil-society participation, FPIC for Indigenous and other rights holders, clear
  grievance mechanisms, and adherence to OECD and EU due diligence standards across supply chains.
• Addressing underlying drivers of demand by promoting sufficiency (smaller vehicles and batteries, modal shift to public transport) and stricter product
  lifetime and EPR requirements.

Overall, the report concludes that a resilient and just EU battery value chain is technically achievable if recycling and circular strategies are prioritized, legal
safeguards are reinforced rather than weakened, and SLO becomes a central governance criterion rather than an afterthought.