Implications for Battery RecyclingThe rule poses particular challenges for recycling of LIBs because there is very limited capacity in the U.S. to process black mass to recover critical minerals. Without the ability to ship black mass to the foreign refiners, there will be no way to fully recover critical minerals from LIBs for the foreseeable future. For this reason, domestic companies that collect and process LIBs to produce black mass are likely to move quickly to request adjustments or exceptions from the prohibition. The same is true for brokers currently involved in exporting black mass. A prior B&D news alert, “China and Europe Diverge on Classification of Black Mass from Recycling of Lithium-Ion Batteries,” discusses varying approaches that different countries have started to take on classification of LIBs and black mass.