ReMA's Wiener addresses export controls on black mass and tungsten

The Recycled Materials Association's Wiener has discussed export controls covering black mass and tungsten, two material streams now sitting at the center of U.S. trade and critical-minerals policy. The discussion, reported by Recycling Today, puts the association on record at a moment when processors, traders and regulators are all reassessing where these commodities are allowed to flow.

The subject matter is narrow but consequential. Black mass and tungsten are the two recycled streams named in the exchange, and both carry policy weight far beyond their tonnage.

Why does black mass matter to the export debate?

Black mass is the shredded intermediate output of end-of-life lithium-ion batteries. It contains recoverable lithium, nickel and cobalt. Whether that material leaves the country or stays for domestic processing has become a defining question for the North American battery recycling buildout.

Export controls on the stream would redirect material toward domestic hydrometallurgical capacity. The trade-off is straightforward. Processors that ship black mass abroad gain access to established refining capacity today. Restricting that flow protects, or creates, demand for domestic plants that in several cases are still under construction rather than operating.

The association's engagement on the question signals that its members do not speak with one voice on the issue. Traders and early-stage processors benefit from open export channels. Companies investing in domestic refining want the feedstock kept home.

What is at stake with tungsten?

Tungsten occupies a different position in the same conversation. The metal is classified as a critical mineral, with recycled tungsten carbide scrap a meaningful share of Western supply. Export controls on the stream touch hardmetal recyclers, machine shops and swarf processors, along with the smelters that consume their output.

Wiener's decision to treat black mass and tungsten together frames both as test cases for how export policy gets written for recycled commodities. Each stream raises the same structural question: whether recycled material counts as waste to be restricted, feedstock to be secured, or a traded good subject to standard commerce rules.

What does the industry want from regulators?

The association's position, as presented by Wiener, is that the industry needs clarity and consistency in how export controls are designed and applied. Recycled materials differ from mined ores and virgin inputs in how they move, and controls drafted without accounting for that difference risk cutting off legitimate trade lanes.

That argument lands on regulators who are simultaneously pursuing two goals: securing domestic supply chains for critical minerals and avoiding disruption to the recycling operators who feed them. The two goals align when domestic capacity exists to absorb the material. They conflict when it does not.

The timing matters. Investment decisions in battery recycling and tungsten recovery are being made now, and each decision rests on an assumption about where material will be permitted to flow. Policy uncertainty is itself a cost.

What comes next?

The immediate milestone is procedural rather than industrial. Export control policy for these streams will be decided in rulemaking and enforcement practice, not in association commentary, and the specifics of any restriction — scope, thresholds, licensing requirements — will determine which facilities capture the material and which lose access to it.

For the recycling sector, the benchmark to watch is whether black mass and tungsten controls are written as narrow security measures or as broad constraints on scrap trade. That drafting choice, more than any pledge or position statement, will set the shape of both material streams for the plants being financed today.