June 10, 2026 | Enji | Mongolia Circular Battery Initiative (MCBI) | Policy Commentary
As global competition intensifies to secure critical minerals essential for the energy transition, the policy tools governing what happens to those minerals after they enter a battery remain dangerously underdeveloped. Extended Producer Responsibility (EPR) offers an effective framework to fill this gap and for mineral-rich countries like Mongolia, designing EPR correctly is not merely a regulatory question: it is a strategic economic and environmental priority.
The Global Landscape: EPR Is Accelerating
Regulatory momentum around battery EPR has grown sharply in recent years.
In the European Union, the EU Batteries Regulation (EU 2023/1542) entered into force in August 2023, with core EPR and labeling obligations applying to member states from August 2025. Requirements span the full battery lifecycle: collection targets, recycling efficiency standards, producer registration obligations, and take-back schemes. Supply chain due diligence rules covering cobalt, natural graphite, lithium, and nickel are being phased in as a central pillar of the regulation.
In the United States, the EPA and Department of Energy have developed voluntary EPR frameworks for all battery types under the Infrastructure Investment and Jobs Act. A series of stakeholder consultations ran from 2025 into early 2026, addressing recycling targets, cost structures, product design, and collection models. Several states including Vermont, Illinois, Colorado, Oregon, and Washington — have passed new battery EPR legislation taking effect in 2026.
The direction is clear: EPR is becoming the primary government instrument for assigning end-of-life responsibility to battery producers.
What EPR Does and Why It Matters for Critical Mineral Recovery
EPR shifts the financial and operational burden of waste management from governments and taxpayers to the companies that originally placed products on the market. For batteries, this means manufacturers and importers are responsible for collection, sorting, and processing of used batteries rather than allowing them to be discarded through informal channels.
This affects critical mineral recovery through three distinct pathways:
1. Creates economic incentives for design-for-recycling. When producers bear end-of-life costs, they have a direct financial incentive to design batteries that can be efficiently disassembled and yield recoverable quantities of lithium,
nickel, cobalt, manganese, and graphite. Without EPR, these costs fall on municipal and informal waste systems.
2. Generates domestic secondary supply of critical minerals. The IEA estimates that by 2040, materials recovered from recycled batteries could reduce new primary mining demand for key minerals by approximately 10%. Domestic recycling infrastructure financed and organized through EPR mechanisms enables recovered minerals to re-enter supply chains rather than being lost to landfill or exported as waste.
3. Builds the institutional infrastructure that mineral-rich countries need. For countries like Mongolia both a mineral exporter and an emerging battery importer an EPR framework establishes the governance architecture to systematically track, collect, and process battery waste. Without this infrastructure, the long-term value of critical mineral reserves is captured elsewhere in the supply chain.
Mongolia’s Position: A Policy Opportunity Not Yet Seized
Mongolia sits at a distinctive crossroads. It holds significant reserves of lithium, copper, fluorspar, and rare earth elements critical to battery manufacturing while simultaneously experiencing rapid growth in EV and consumer electronics use. Mongolia’s current legal framework, the 2017 Waste Law, contains no specific provisions governing lithium-ion or EV battery waste. There is no mandatory producer registration, no collection targets, and no dedicated recycling infrastructure operating under EPR principles.
This regulatory gap carries real risks. Batteries discarded through informal channels leach heavy metals and electrolyte compounds into soil and groundwater. Batteries containing minerals that could be recovered are being landfilled rather than processed. As EV adoption grows, the volume of end-of-life batteries entering the waste stream will increase substantially over the coming decade.
The opportunity, however, is equally significant. Mongolia can learn from both the successes and implementation challenges observed in EU and US practice and design an EPR framework from the outset that reflects Mongolian institutional realities, rather than retrofitting models designed for different contexts.
MCBI’s Approach: Building EPR-Compatible Systems
The Mongolia Circular Battery Initiative (MCBI) is working to demonstrate at pilot scale and ahead of comprehensive legislation what a collection and recovery system for used batteries could look like under Mongolian conditions.
This matters because EPR frameworks do not emerge from legislation alone. They require logistics (collection points, transport, sorting), technical capacity (battery chemistry analysis, processing capability), and stakeholder trust (among producers, retailers, local government, and recyclers). MCBI’s Czech-Mongolian partnership model is specifically designed to transfer established circular economy knowledge and operational experience from the EU context to Mongolian conditions laying the foundation that future EPR regimes will require.
MCBI is also engaged with the Ministry of Environment and Climate Change on the policy architecture needed to close current regulatory gaps, including the rationale for an inter-ministerial working group coordinating the Ministries of Mining, Finance, and Industry and Digital Development on battery waste governance.
Key Policy Recommendations
For policymakers in Mongolia and comparable mineral-rich countries in early stages of battery EPR planning, MCBI identifies the following priorities:
• Make producer registration the first legal step. Before collection targets can be enforced, it must be clear in mandatory, enforceable terms who bears responsibility: not only domestic manufacturers but importers.
• Design collection infrastructure for low-density conditions. EPR collection models developed for dense urban environments in the EU or US require adaptation. Mongolia’s geography demands a different approach: decentralized intake points, return logistics partnerships, and mobile collection to complement fixed infrastructure.
• Integrate mineral recovery from the outset. EPR frameworks that treat used batteries only as waste miss the economic opportunity. Expressing recovery targets in terms of mineral yield not only battery weight aligns incentives with critical mineral strategy.
• Ensure inter-ministerial coordination. Battery waste governance intersects environmental regulation, mining law, trade policy, and industrial development. Single-ministry approaches produce incomplete frameworks. Inter-ministerial coordination mechanisms are essential.
• Build bilateral and multilateral knowledge partnerships. Mongolia’s emerging EPR framework will benefit from exchange with countries operating comparable systems. EU-Mongolia relations including MCBI’s Czech partnerships represent a practical channel for this exchange.
Conclusion
Battery EPR is no longer a future policy option — it is regulatory reality in major markets. For Mongolia, the question is not whether to develop an EPR framework for critical mineral recovery, but how to design one that reflects Mongolian geography, institutional capacity, and strategic mineral interests.
MCBI remains committed to contributing to that design through pilot demonstration, policy engagement, and knowledge-sharing partnerships with the EU’s circular economy ecosystem.
Mongolia Circular Battery Initiative (MCBI) is a circular economy initiative focused on battery recycling, critical mineral recovery, and sustainable resource governance, operating between the Czech Republic and Mongolia. Learn more at mcbis.org.
