In view of the new EU Battery Regulation, battery manufacturers will need to adopt their business models to comply with the mandatory minimum recycled material content levels for new battery cells by the end of the decade. According to our research, there are at present no recycled materials on the open market that would fulfill these guidelines of the EU Battery Regulation, and therefore prompting manufacturers to seek individual solutions. One possible approach is the production of their own recycled materials by directly recycling production waste from battery cell production, which is beneficial as the waste is already generated and its composition [1] and material properties [2] are known.
At present, direct recycling is still in the development phase [3] and there is no universal state-of-the-art process route. Numerous challenges remain to be addressed in the implementation of a direct scrap recycling process [4], including scaling up and validating the process routes on a large scale. Additionally, the question of what possible future business models might look like has also not yet been answered.
Therefore, this work depicts the status and challenges associated with implementing a direct recycling process route for battery production scrap. The EU Battery regulation and possible business models for battery recycling are analyzed. In conclusion, recommendations for actions to implement direct recycling processes into battery cell manufacturing are presented.

References
[1] Gaines, L., Dai, Q., Vaughey, J. T., & Gillard, S. (2021). Direct Recycling R&D at the ReCell Center. Recycling, 6(2), Article 31. https://doi.org/10.3390/recycling6020031
[2] Yu, L., Bai, Y., Polzin, B., & Belharouak, I. (2024). Unlocking the value of recy-cling scrap from Li-ion battery manufacturing: Challenges and outlook. Journal of Power Sources, 593, Article 233955. https://doi.org/10.1016/j.jpowsour.2023.233955
[3] Chen, M., Ma, X., Chen, B., Arsenault, R., Karlson, P., Simon, N., & Wang, Y. (2019). Recycling End-of-Life Electric Vehicle Lithium-Ion Batteries. Joule, 3(11), 2622–2646. https://doi.org/10.1016/j.joule.2019.09.014
[4] Ahuis, M., Aluzoun, A., Keppeler, M., Melzig, S., & Kwade, A. (2024). Direct recycling of lithium-ion battery production scrap – Solvent-based recovery and reuse of anode and cathode coating materials. Journal of Power Sources, 593, Article 233995. https://doi.org/10.1016/j.jpowsour.2023.233995