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★Mark us as a preferred sourceBattery waste status is not a topic that usually reaches a stock exchange newsfeed, yet that is exactly what happened in early September 2026, when ALTEO Energiaszolgáltató Nyrt. published an announcement on the website of the Budapest Stock Exchange informing investors that two of its group companies had turned to the courts against waste management fines imposed by the Nógrád County Government Office.
The dispute is not an administrative formality. It turns on a single question: at what point does a used lithium-ion battery unit cease to be a product and become, in legal terms, waste. In Hungary today that question affects the fate of several hundred megawatt-hours of potential storage capacity and the room for manoeuvre of the entire second-life sector.
Two separate lawsuits, HUF 54.4 million in fines
According to the announcement, ALTEO Circular Kft., a subsidiary of ALTEO Nyrt., and Peregium Green Zrt., majority-owned by ALTEO Circular, each filed separate administrative lawsuits against the decisions addressed to them.
The fines imposed:
- Peregium Green Zrt.: HUF 50.2 million
- ALTEO Circular Kft.: HUF 4.2 million
The authority’s reasoning, as summarised in the announcement, rests on three elements: failure to comply with the classification obligation attached to the batteries, meaning their reclassification into waste status; treatment of the units as products; and their removal from the site as products.
The companies dispute, on technical grounds, the classification of the batteries as waste, and in the case of Peregium Green they also dispute the quantity taken as the basis for calculating the fine. That second point matters on its own: Hungarian waste management fines scale with quantity, so the quantitative argument could materially affect the amount even if the authority’s position on status prevails.
The core of the legal dispute
Waste status is decisive because it is binary. An object is either a product or waste, and two radically different regulatory regimes follow. If the units qualify as waste, the holder must classify them with particular attention to hazardous components, may only transport them under waste shipment documentation to a permitted treatment operator, and must meet technical protection requirements for storage. If they are products, none of that applies; product safety and placing-on-the-market rules apply instead.
The definition of waste comes from Directive 2008/98/EC and, in Hungary, from the national Waste Act. It is built on the holder’s conduct and intention: waste is any substance or object which the holder discards, intends to discard or is required to discard. That criterion generates interpretation disputes on its own whenever equipment is still technically functional but is no longer used for its original purpose.
ALTEO’s argument: the EU Battery Regulation and repurposing
The centrepiece of the companies’ position, as set out in the announcement, is Regulation (EU) 2023/1542. In ALTEO’s account, the Regulation follows technological development by naming the concept of repurposing: an operation resulting in a battery that is not a waste battery, or parts of it, being used for a purpose or application other than the one it was originally designed for.
According to the announcement, the Regulation thereby created a legal category in which a battery given a new, different function or put to a different use does not qualify as waste, and is instead treated by the Regulation as a distinct, expressly recognised operation. On that basis, the companies say, they handled the batteries as products and sold and shipped the units for further use in electricity storage systems.
The announcement adds that this reuse extended the service life of functioning batteries and reduced the emissions and environmental burden linked to extracting and processing virgin raw materials.
This reading stands against the position reflected in the authority’s decisions, according to which the units should have been classified as waste. Which of the two readings holds on these particular facts — that is, how the Battery Regulation’s concepts relate to the statutory definition of waste — is the subject of the administrative proceedings now under way. That question is for the court to decide.
Background at the Salgótarján site
The announcement does not name the site, but the case has been documented in detail in the Hungarian press. Reports by Átlátszó and other outlets describe several hundred tonnes of battery units, largely stored in the open air for years, at a Salgótarján site previously associated with Éltex Kft. In March 2026 the Nógrád County Government Office ordered the owners to classify the stock as waste, with particular attention to hazardous components, and then to remove it and hand it over to a permitted waste treatment operator.
According to press reports, the authority questioned the product status on several grounds: batteries recalled from vehicles could, in its view, have retained product status only for automotive use; the technical documentation submitted was found inadequate; and less than half of the stock was processed over the entire period of the investigation, which the authority saw as pointing to experimental rather than industrial-scale activity. The penalty decisions also found bad faith and an economic advantage gained through the infringement. The remaining volume was eventually removed from the site, with shipping documents recording the movements as product sales.
These are the authority’s findings, and they are precisely what the companies are now contesting before the courts. Until judgment, neither side’s account can be treated as conclusively established.
Why this matters beyond one company
Second-life energy storage is one of the most promising and, legally, least settled elements of Europe’s circular battery strategy. Batteries leaving electric vehicles typically retain 70–80% of their original capacity, which is too little for mobility but sufficient for grid or industrial storage for years to come. Where that route works, the useful life of the units is extended and the burden associated with raw material extraction is pushed further out.
The practical obstacle is exactly the status question. Under EU law, end-of-waste status is subject to strict cumulative conditions, and there are currently no harmonised EU end-of-waste criteria for batteries. Classification therefore often comes down to case-by-case administrative judgement, which creates unpredictability for investors. The companies argue that in the Hungarian market it is essential for the legal framework and administrative practice to support sustainable secondary use rather than obstruct it.
The regulator’s logic also rests on rational grounds. In practice, an appeal to a second life can be abused: if a mere declaration of intent were enough to maintain product status, part of any accumulated, untreated stock could be permanently removed from waste records and oversight. With large volumes of lithium-ion units stored outdoors, that also carries fire and soil contamination risk.
Requiring documented, verifiable processing performance is therefore not formalism. At system level, it is what separates genuine reuse from operations that only look like reuse.
What happens next
Two parallel remedies are running. The first is the administrative litigation against the penalty decisions, in which the court reviews their lawfulness. The second is a supervisory procedure before the National Green Authority, in which the companies are seeking review of the binding decisions establishing waste status, which have already become final.
A supervisory procedure is an extraordinary remedy: it does not depend on an open appeal window, but on the superior body identifying a breach of law within its own competence and amending or annulling the lower-level decision on that basis.
The stakes go well beyond HUF 54.4 million. A court ruling that touches on the relationship between waste status and the Battery Regulation could set the reference point for every Hungarian operator building storage assets from used batteries.
What to watch
- Whether the court separates the quantitative question of the fine base from the substantive question of status.
- How case law positions the Battery Regulation’s concept of repurposing against the Waste Framework Directive’s definition of waste.
- What standard of proof the authority requires to maintain product status: whether an intention to recover suffices, or documented industrial-scale processing performance is needed.
- Whether harmonised EU or national end-of-waste criteria for batteries are developed, which would resolve the substantive part of the legal uncertainty.
Frequently asked questions about battery waste status
Why did ALTEO’s two companies go to court?
ALTEO Circular Kft. and Peregium Green Zrt. each filed separate administrative lawsuits against the decisions of the Nógrád County Government Office imposing waste management fines. The companies dispute the classification of the batteries as waste and, in Peregium Green’s case, the quantity used as the basis for the fine. They argue the units were lawfully handled as products for further use in electricity storage systems.
What does a waste status determination mean in practice?
It means the authority considers the units to be waste in legal terms rather than products. The holder must then classify them with particular attention to hazardous components, may only transfer them under waste shipment documentation to a permitted treatment operator, and must meet technical protection requirements for storage. Under product status, product safety rules apply instead.
What does ALTEO invoke from the EU Battery Regulation?
According to ALTEO’s announcement, Regulation (EU) 2023/1542 names the concept of repurposing: an operation resulting in a battery that is not a waste battery, or parts of it, being used for a purpose other than the one originally intended. The companies argue that the Regulation thereby treats such reuse as a distinct, expressly recognised operation. Whether it applies here is for the court to assess.
How large were the fines imposed?
The Nógrád County Government Office imposed a waste management fine of HUF 50.2 million on Peregium Green Zrt. and HUF 4.2 million on ALTEO Circular Kft., totalling HUF 54.4 million. The reasoning was that the companies failed to comply with the classification obligation attached to the batteries and handled and removed the units from the site as products.
What is a supervisory procedure before the National Green Authority?
A supervisory procedure is an extraordinary remedy. It does not depend on an open appeal window, but on the superior body identifying a breach of law within its own competence and then amending or annulling the lower-level decision. The companies are using it to seek review of the already final decisions establishing waste status.
Sources:
ALTEO Energiaszolgáltató Nyrt. stock exchange announcement (Budapest Stock Exchange); Regulation (EU) 2023/1542 concerning batteries and waste batteries; Directive 2008/98/EC on waste; reporting on the Salgótarján case by Portfolio.hu, Átlátszó.hu and 10perc.hu.
