Why Europe needs its own graphite, and what EU rules now require

Graphite is the quiet giant in every battery

Discussions about battery materials usually focus on lithium, nickel and cobalt. Yet the anode of almost every lithium-ion cell is graphite, and by mass it is the largest single active material in the cell. Graphite stores lithium between its carbon layers at a potential close to that of lithium metal, it changes volume by only about 10% when it takes up lithium, and it does so over thousands of cycles. That combination is why it has remained the standard anode since the early 1990s, with silicon added in small amounts to raise capacity (Asenbauer et al., 2020).

Battery-grade graphite comes in two forms. Natural graphite is mined as flakes, purified to above 99.95% carbon with acids or at high temperature, milled into rounded particles and coated. Synthetic graphite is made from petroleum coke or needle coke that is baked and then graphitised at temperatures well above 2,500 °C, a slow step that uses a great deal of electricity. Both routes need many processing steps, and that is where supply is concentrated.

One country makes almost all of it

China mined about 78% of the world's natural graphite in 2024, according to US Geological Survey data (IISD, 2026). Its lead in processing is larger still. The International Energy Agency estimates that China supplied about 94% of the world's battery-grade graphite in 2025, and expects that share to fall only to around 91% by 2035 as new capacity comes online elsewhere (IEA Global Critical Minerals Outlook 2026, as reported). Industry trackers put Chinese companies' share of anode material shipments at around 94 to 95% (SNE Research, as reported).

No other major battery material is this concentrated. For a European cell factory, the largest ingredient in its product depends on one supplier country, with long shipping routes and little room to switch.

Export controls made the risk real

In December 2023 China began requiring export licences for several graphite products. In October 2025 its Ministry of Commerce announced controls on artificial graphite anode materials, on blends of artificial and natural graphite, and on the equipment and process technology used to make them, effective 8 November 2025 (Thomson Reuters, October 2025). Weeks later the new controls were suspended for one year as part of wider trade talks, a pause due to run until November 2026 (SMM, October 2025).

Licences, pauses and reversals make long-term planning hard. A battery maker signing a supply contract today cannot know on what terms the material will be allowed to leave the country in three years.

Three EU laws that shape the market

1. The Critical Raw Materials Act (Regulation (EU) 2024/1252) names 17 strategic raw materials. Battery-grade graphite is one of them, covering both natural and synthetic graphite, with the strategic status of synthetic graphite to be reassessed (Fastmarkets, 2024). For each, it sets non-binding benchmarks for 2030, measured against the EU's annual consumption (Council of the EU):

• at least 10% from extraction in the EU
• at least 40% from processing in the EU
• at least 25% from recycling in the EU
• no more than 65% from any single non-EU country, at any stage of processing

The Act also creates Strategic Projects, which get permits within 15 months for processing and recycling and easier access to finance. For graphite, processing and recycling are the furthest from target: Europe has little of either today, and graphite is barely recycled at commercial scale.

2. The Batteries Regulation (Regulation (EU) 2023/1542) covers the whole life of a battery. For materials it sets recovery targets for recyclers (lithium 50% by the end of 2027 and 80% by the end of 2031; cobalt, copper, lead and nickel 90% and then 95%) and minimum recycled content in new industrial and electric vehicle batteries from August 2031 (16% cobalt, 6% lithium, 6% nickel), rising in 2036 (26%, 12% and 15%). It also requires due diligence on the supply of lithium, cobalt, nickel and natural graphite, and carbon footprint declarations for electric vehicle batteries. Graphite is not yet among the recycled content targets, but the regulation provides for the targets to be reviewed.

3. Black mass as hazardous waste. In March 2025 the Commission updated the European List of Waste and classified black mass as hazardous (European Commission, 2025). Because the EU bans exports of hazardous waste to non-OECD countries, black mass now has to be treated in Europe or another OECD country. The new waste codes become mandatory for operators from November 2026 (EUWID, 2025).

What it adds up to

Each rule alone is a benchmark or a restriction. Together they reward one thing: recovering more value from Europe's own waste streams, close to where batteries are made. Europe has few graphite mines, but it will soon have large volumes of spent batteries and factory scrap. Each tonne of black mass holds several hundred kilograms of graphite that has already been mined, purified and shaped once. Recovering it counts towards the recycling benchmark, it is processed in Europe, and it does not depend on export licences.

The condition is quality. Battery makers accept recovered graphite only if it performs like what they use today. See what makes graphite battery grade.

Where Aeroborn fits

Aeroborn recovers graphite from black mass in Rotterdam and purifies it to battery grade at 99.95% carbon, on a patented platform. It gives European cell makers a source of anode graphite that is made in Europe, from European waste. See battery-grade graphite or discuss a material.