From Waste to Value: Building Europe’s Market Infrastructure for Second-Life EV Batteries
Europe has built ambitious rules for circular batteries, but regulation alone does not create functioning markets. As growing volumes of EV batteries leave vehicles with useful life remaining, fragmented diagnostics, valuation, regulation, logistics and cross-border processes risk leaving valuable capacity stranded or prematurely recycled. Rebattex estimates that up to 180 GWh could become accessible by 2035. The paper argues that Europe must develop the “missing middle”: trusted market infrastructure connecting manufacturing and recycling through repair, reuse, remanufacturing and repurposing, supported by common standards, traceability, regulatory clarity and digital transaction infrastructure.
This policy paper examines the gap between Europe’s ambitious circular battery regulation and the practical market mechanisms needed to implement it. It explores the emerging “missing middle” between battery manufacturing and recycling, where EV batteries may retain significant technical and economic value through repair, reuse, remanufacturing or repurposing. The paper analyses key barriers including fragmented diagnostics, uncertain battery status and liability, limited valuation methods, data interoperability and complex cross-border transactions. It sets out eight policy priorities for
creating a trusted European second-life battery market and argues that market infrastructure should be recognised as an essential part of Europe’s circular and industrial battery strategy.