New Black Mass Export Rules: Will They Help or Harm the Lithium-ion Industry
Unpacking the new export rules, domestic supply chain loopholes, and the race to secure America's recycled battery metals.
What is black mass?
The Bureau of Industry and Security (BIS), an agency in the Department of Commerce, issued a new temporary rule, the Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials, which provides a legal definition of black mass within the context of the rule.
For purposes of this Directive Allocation Order, ‘black mass’ means any shredded lithium-ion battery scrap that contains cathode material (which may include lithium, cobalt, nickel and manganese), anode material (graphite, silicon) or other residual battery cell materials.
While that definition explains what black mass is made of, it doesn’t show why it’s critical to the domestic supply chain or where and how it fits into the lithium-ion industry.
A recycler’s feedstock comes from two main sources: end-of-life batteries, or manufacturing scrap generated during production. Manufacturing scrap is further split into two categories: dry scrap (foil clippings and components produced before electrolyte is added) and wet scrap (material rejected after the electrolyte is injected).
Unlike what the general public believes, while the electrolyte contains lithium, it is not the lithium itself that poses the highest safety risk during recycling. Rather, the electrolyte itself does. When heated or exposed to air and moisture, the chemicals in the electrolyte break down into toxic, flammable gases. The severity varies based on chemistry and state of charge.
High-nickel versus lithium iron phosphate chemistries produce different gas profiles. State of charge determines not just how much gas is produced, but which gases and at what concentrations, with specific test data showing that lower state of charge thresholds in chemistries like lithium iron phosphate can yield distinct toxic gas concentrations compared to higher-charged ternary cells.
However, you can’t just crack open a battery, dump the contents into a bucket, and feed the materials into a lithium-ion production line. The materials are physically and chemically locked into complex structures. That is where the mechanical component of lithium-ion recycling comes into play. After disassembly, the cells are shredded, and that is when the black mass is created.