“The entire export debate comes down to one question: is black mass a hazardous waste or a secondary raw material? The answer defines the exporter’s obligations and whether shipment outside the EU is even possible.” - Ignacy Heckert
Key Legal Insights on Sustainable Mobility
The largest sustainable mobility and clean energy event in Central and Eastern Europe gathered innovators, policymakers, and industry leaders - and Dudkowiak & Putyra Business Lawyers were among the key contributors.
Legal Counsels Ignacy Heckert and Anna Cichoń contributed to the official programme with expert insights into two of the sector’s most pressing topics: black mass recycling and hydrogen deployment.
Exporting Black Mass Outside the EU
Ignacy Heckert delivered a session titled “Exporting Black Mass Outside the EU - Legal Loophole or Circular Economy in Action?” His presentation explored the evolving legal status of black mass under EU law, including its upcoming classification as hazardous waste starting November 9, 2026.
This regulatory change will significantly restrict cross-border shipments, particularly to OECD countries such as South Korea and non-OECD countries like Morocco.
The debate sparked strong interest among recycling companies, battery producers, and compliance officers, underlining the strategic importance of black mass as a critical raw material containing lithium, cobalt, nickel, and manganese.
Hydrogen and Energy Storage Roadmap
As part of the Hydrogen and Energy Storage Technology Committee, Anna Cichoń contributed to the forthcoming report “The State of Hydrogen Technology Implementation in the Transport Sector,” scheduled for publication on October 15, 2025. The report will outline current progress, key regulatory and technological challenges, and recommendations for scaling hydrogen use in aviation, maritime, rail, and road transport.
Beyond the formal sessions, Anna and Ignacy also engaged in discussions on hydrogen’s potential for military and defence applications, highlighting growing interest in dual-use clean energy solutions.
Advisory for Industry Stakeholders
With black mass export rules tightening and hydrogen regulations developing rapidly, Dudkowiak & Putyra advises clients on navigating these complex legal frameworks.
Do you need legal help?
If your organisation faces legal, regulatory, or strategic questions related to black mass, hydrogen technologies, or dual-use energy solutions, our team is here to help.
