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Our Experts at New Mobility Congress 2025: Black Mass, Hydrogen, and the Law

 

Dudkowiak & Putyra at New Mobility Congress 2025: Black Mass, Hydrogen, and the Law

We are proud to announce that our Legal Counsels, Ignacy Heckert and Anna Cichoń, represented our law firm at the 2025 Polish New Mobility Association Congress
– one of Central and Eastern Europe’s leading events focused on sustainable transport, e-mobility, and clean energy technologies.

As part of the official conference programme, Ignacy delivered a presentation titled:

“Exporting Black Mass Outside the EU – Legal Loophole or Circular Economy in Action?”

His talk addressed the evolving legal status of  black mass under EU law, recent changes to its classification as hazardous waste, and the regulatory consequences for cross-border shipments – particularly to OECD countries such as South Korea, and non-OECD countries like Morocco.

The session sparked wide interest, particularly among recycling companies, battery producers, and environmental compliance officers.

Quick Fact: What Is Black Mass?

Black mass is a powdery, metal-rich substance generated during the recycling of lithium-ion batteries. It contains valuable critical raw materials such as lithium, cobalt, nickel, and manganese – all essential for battery cell manufacturing.

Although its strategic importance is widely recognised, black mass will be classified as hazardous waste under EU law starting from 9 November 2026 – a change that will significantly restrict the possibility of exporting and processing it outside the EU without meeting strict regulatory requirements.

The debate on the legal classification of black mass in the EU centers on the question of whether it should be treated as hazardous waste or as a secondary raw material intended for further use in the production process.

Save the Date: October 15

As part of the Congress agenda, Anna Cichoń participated also in a formal session of the Hydrogen and Energy Storage Technology Committee, where experts discussed strategic priorities for advancing hydrogen solutions across the transport sector.

We’re pleased to share that the outcome of the committee’s work will be published in a comprehensive final report,

“The State of Hydrogen Technology Implementation in the Transport Sector,”

scheduled for release on October 15, 2025.

Anna was a contributing member of the working group behind this publication, which provides a detailed overview of the current state of hydrogen deployment in European transport. The report also identifies key regulatory and technological challenges and presents actionable recommendations to support the scale-up of hydrogen technologies in the aviation, maritime, rail, and road sectors.

We will be sharing the full report and further insights on our channels following its official release.

Beyond the formal agenda, our team also engaged in fruitful, off-panel discussions with industry stakeholders on the potential use of hydrogen technologies in military and defence applications. These forward-looking conversations highlighted growing interest in the dual-use potential of clean energy solutions – particularly in areas such as mobility, storage, and operational independence.

Do you need legal help?

If your organization is navigating legal, regulatory or strategic questions related to black mass exports, military advise or hydrogen technologies, our team is here to help.

Author team leader D&P Legal Michał Puk
Contact our expert
Write an inquiry: [email protected]
check full info of team member: Michał Puk

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