What does recycler mean?
Recycler is a recovery-actor term, not every waste handler and not just any company dealing with used batteries. EU Battery Regulation, India Battery Waste Management Rules, and Brazil CONAMA Resolution 401/2008 recycler concepts are not interchangeable; under the EU Battery Regulation the recycler actually carries out recycling in a permitted facility.
Source context
This page combines EU Battery Regulation, India Battery Waste Management Rules, and Brazil CONAMA Resolution 401/2008 layers. Keep recycler separate from collection, transport, treatment-operator approval, refurbishment, waste management, and recycling-efficiency calculations. It is not the same as collection or general waste handling.
Official definitions by source
EU Battery Regulation
Regulation (EU) 2023/1542 concerning batteries and waste batteries
any natural or legal person who carries out recycling in a permitted facility;
Reference: Article 3, point 58
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India Battery Waste Management Rules
Battery Waste Management Rules, 2022
entity engaged in recycling of Waste Battery;
Rule 3(1)(w) of the India Battery Waste Management Rules, 2022. India-specific source layer; compare with other jurisdictions before reusing as a general definition.
Reference: Rule 3(1)
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Brazil CONAMA Resolution 401/2008
CONAMA Resolution No. 401 of 4 November 2008
pessoa jurídica devidamente licenciada para a atividade pelo órgão ambiental competente que se dedique à recuperação de componentes de pilhas e baterias
Brazil source-specific definition; Portuguese text is authoritative and the English translation is a draft Minespider working translation.
Reference: Article 2, point X
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EU Critical Raw Materials Act
Regulation (EU) 2024/1252 establishing a framework for ensuring a secure and sustainable supply of critical raw materials
any natural or legal person who carries out recycling in a permitted facility
CRMA Article 2 source-specific definition layer.
Reference: Article 2, point 58
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Definition status
Reviewed public draft page. Aligns with EPR/recycling responsibility policy: separates producer obligations, scheme evidence, recycling actor roles, repurposing transitions, waste-management quality, and process-yield proof.
How the definitions differ
Recycler is the actor or facility responsible for carrying out recycling operations that convert waste materials or batteries into recovered material outputs under the relevant source regime.
Practical application
Implementation records should capture recycler identifier, facility permit, input batch, output material record, waste stream, process type, acceptance date, recycling date, mass balance, recovery/recycling result, and certificate or evidence file.
Minespider commentary
Recycler is a downstream proof point and recovery-actor control for circularity evidence. It should link waste inputs, permitted facilities, processes, output materials, and mass-balance records so recycling claims can be traced beyond handover.
Common confusions
- Treating every collector, transporter, broker, treatment operator, or regional recycler definition as interchangeable with the EU Battery Regulation recycler actor.
- Recording recycling proof without input batch, permitted facility, process, output material, and mass-balance evidence.
- Assuming recycler status means the material has met a specific recycled-content or end-of-waste threshold.
- Treating recycling as the same as collection, transport, brokerage, or storage without evidence of the permitted recycling operation.
Related regulations
Related terms