Why Recycled Content Plays a Key Role in the Battery Passport
The EU Battery Regulation (EU) 2023/1542 makes the use of recycled raw materials in batteries not merely a recommendation, but a legal obligation. From 2031, battery manufacturers must demonstrate that minimum percentages of cobalt, lithium, nickel, and lead come from recycled sources and document these values in the battery passport.
Particularly relevant for storage manufacturers: see all obligations on the battery passport for energy storage page.
This makes the battery passport the central verification instrument for circular economy in the battery sector. Those who fail to meet the quotas or don't document them correctly risk losing EU market access.
Mandatory Recycling Quotas at a Glance
The EU Battery Regulation defines binding minimum shares of recycled material in two stages:
Stage 1: from 18 August 2031
- Cobalt: at least 16% from recycling
- Lead: at least 85% from recycling
- Lithium: at least 6% from recycling
- Nickel: at least 6% from recycling
Stage 2: from 18 August 2036
- Cobalt: at least 26% from recycling
- Lead: at least 85% from recycling
- Lithium: at least 12% from recycling
- Nickel: at least 15% from recycling
These quotas apply to industrial batteries > 2 kWh, EV batteries, and LMT batteries.
Which Batteries Are Affected?
The scope of Article 8 is not the same as the scope of the battery passport:
- Electric vehicle batteries (EV): Traction batteries for e-cars, e-motorcycles
- Industrial batteries > 2 kWh: Stationary storage, UPS, energy storage systems
- SLI batteries: Starter, lighting and ignition batteries, which need no battery passport
- LMT batteries: For e-bikes, e-scooters, and similar light means of transport
For LMT batteries the documentation duty applies only from 18 August 2033, and the minimum quotas reach them only with stage 2 in 2036 (Article 8(1) and 8(3)). For details on LMT requirements, see our article Battery Passport for E-Bikes and E-Scooters.
How Is Recycled Content Documented in the Battery Passport?
DIN DKE SPEC 99100 assigns recycled content to the Circularity and Resource Efficiency (Section 6.6) domain. The following data must be captured in the battery passport:
- Pre-consumer recycled content: Share of production waste reintroduced into manufacturing
- Post-consumer recycled content: Share of material from end-of-life products
- Breakdown by raw material: Separate figures for cobalt, lithium, nickel, and lead
- Third-party verification: Carried out by independent conformity assessment bodies
Recycled content is stated as a percentage of total weight of the respective raw material in the battery. The calculation follows methods defined in the regulation and must be verified by an accredited conformity assessment body.
Recovery Rates: What Recyclers Must Achieve
Alongside recycled content requirements for manufacturers, the regulation also defines minimum recovery rates for recycling companies:
By 31 December 2027
- Lithium: at least 50% recovery
- Cobalt, copper, lead, nickel: at least 90% recovery
By 31 December 2031
- Lithium: at least 80% recovery
- Cobalt, copper, lead, nickel: at least 95% recovery
These recovery rates are critical because they are designed to ensure the availability of recycled material for manufacturers. Without sufficient recycling infrastructure, manufacturers simply cannot meet recycled content quotas.
The act that already exists: Regulation (EU) 2025/606
With acts under the Battery Regulation the usual answer is “still pending”. For the recovery rates that is not true: Article 71(4) obliged the Commission to set the calculation method by 18 February 2025, and it delivered. Delegated Regulation (EU) 2025/606 of 21 March 2025 “supplementing Regulation (EU) 2023/1542 ... by establishing the methodology for the calculation and verification of recycling efficiencies and material recovery rates of waste batteries and the format for the documentation” is adopted and in force.
The annex sets out the methodology separately for lead-acid, lithium, nickel-cadmium and other waste batteries, and for the material recovery of cobalt, copper, lead, lithium and nickel. It also contains the format for documenting recycling efficiency, material recovery, destination and yield of the final output fractions.
Why this is still not the manufacturer's own duty
Two terms are regularly mixed up, and the difference decides who is bound:
- Recycled content under Article 8: the share of recovered material IN the new battery. This duty falls on whoever places the battery on the market, and it belongs in the battery passport as an entry.
- Recycling efficiency and material recovery under Article 71 together with Annex XII: the rate a recycling process gets OUT of waste batteries. This duty falls on recycling operators, not on the battery manufacturer, and Regulation (EU) 2025/606 says how to calculate it.
The connection still matters for manufacturers: recovery rates determine how much secondary material exists on the market at all, and that is what your own recycled content has to come from later.
Connection to the Critical Raw Materials Act
The EU Critical Raw Materials Act complements the Battery Regulation with the goal that by 2030, at least 25% of the EU's strategic raw material consumption should come from recycling. For battery manufacturers, this means:
- Cobalt, lithium, and nickel are classified as strategic raw materials
- Demand for recycled material will increase, and potentially prices as well
- Long-term supply contracts with recyclers become a competitive advantage
Manufacturers who build recycling partnerships early secure price advantages and supply security.
The 25% is only one of four targets in Regulation (EU) 2024/1252. By 2030 at least 10% of the EU annual consumption of strategic raw materials is to come from extraction inside the Union and at least 40% from processing inside the Union, while no more than 65% should come from any single third country. The act also sets up ongoing supply chain monitoring with stress tests and puts a risk preparedness obligation on large companies producing strategic technologies.
Timeline: When Does What Apply?
- 18 February 2027: Battery passport becomes mandatory, recycled content must be declared (but no minimum quotas yet)
- 18 August 2028: Recycled content documentation becomes mandatory (recovered shares of cobalt, lithium, nickel, and lead)
- 18 August 2031: Minimum quotas Stage 1 (16% cobalt, 6% lithium/nickel)
- 2033: Recycled content obligations also for LMT batteries
- 18 August 2036: Minimum quotas Stage 2 (26% cobalt, 12% lithium, 15% nickel)
For a complete overview of all deadlines, see our article EU Battery Regulation 2027: Timeline and Obligations.
How Can Manufacturers Prepare?
Even though minimum quotas don't take effect until 2031, manufacturers should start now:
- Identify recycling suppliers: Who provides recycled cobalt, lithium, nickel in your region?
- Build data collection processes: Establish procedures for documenting recycled content in your production
- Prepare battery passport fields: Use tools like DPP Hero that already integrate recycled content fields according to DIN SPEC 99100
- Update supplier contracts: Request recycled content certificates from your material suppliers
Preparing for recycled content requirements is inseparable from general battery passport preparation. Our Battery Passport Checklist guides you through the entire process step by step.
Who the recycled content duty applies to, and from when
Article 8(1) names three groups, and one of them is regularly forgotten: industrial batteries above 2 kWh (except those with external storage only), electric vehicle batteries and starter batteries, meaning the classic SLI batteries. For LMT batteries the same duty applies only from 18 August 2033.
The date is again a double formula: from 18 August 2028 or 24 months after the delegated act enters into force, whichever is later. The Commission should have adopted that act by 18 August 2026. It has not, and the deadline has passed. So do not plan for 2028, plan for 24 months from the day the act actually takes effect.
What the percentage refers to
Not the total weight of the battery. For cobalt, lithium and nickel what counts is the share contained in the active materials. Lead works differently: there it is the share contained in the battery. That distinction is written into Article 8(1) and decides whether your calculation holds up.
The figures are also gathered per battery model, per year and per manufacturing plant, exactly as with the carbon footprint. One value for the whole company is not enough.
Mass balance or physical segregation?
This question decides how expensive implementation becomes, and the Regulation does not answer it. The terms mass balance and chain of custody do not appear in the regulatory text. Article 8(1) expressly refers the method for calculation and verification to the delegated act, which also lays down the format of the documentation.
Until that act exists, nobody can tell you whether book-and-claim allocation suffices or whether you have to segregate material flows physically. Anyone selling a finished recycled content chain of custody today is selling an assumption. What makes sense is to capture supplier data now in a way that keeps both routes open later.
Black mass: the intermediate the recycled-content chain hangs on
Between the spent battery and the recovered cobalt sits a material the Battery Regulation itself never mentions: black mass. It is what remains once spent batteries are dismantled, discharged and shredded, and it carries exactly the metals the recycled-content shares are about, lithium, nickel, cobalt and manganese. Anyone who wants to evidence a share has to know where their black mass comes from and where it goes.
Waste law has just changed here. Delegated Decision (EU) 2025/934 recasts the European waste list for batteries and introduces dedicated codes, among them 16 06 07* for lithium and 16 06 08* for nickel spent batteries. For the intermediate fractions from thermal and mechanical treatment there is a new chapter 19 14: codes 19 14 01* to 19 14 07* carry the asterisk marking them hazardous, and only 19 14 08 for alloys from spent-battery recycling does not. The decision applies from 9 November 2026.
Two things follow in practice. First, shipment gets harder: hazardous waste is subject to stricter rules, and the route to non-OECD countries is closed under the Basel Convention. Second, origin becomes traceable, because each fraction has its own code. For evidencing recycled content in the passport that is help rather than hindrance: document your chain along these codes and you can prove it later.
What evidence is expected, and what belongs in the supply contract
The Regulation is quite precise about the granularity of the evidence. Under Article 8(1), the batteries concerned must be accompanied by documentation stating, per battery model, per year and per manufacturing plant, the recovered share of cobalt, lithium and nickel in the active materials and the lead share in the battery. An annual average across all plants will not do, nor will a figure without a plant reference.
The format of that documentation is for the Commission to set: the same paragraph tasks it with adopting, by 18 August 2026, a delegated act with the calculation and verification method and the format. While that is missing there is no official template; whoever collects today collects on their own structure and should therefore capture granularly enough to re-sort later.
For the supply contract a short list follows. First: the supplier delivers figures at the granularity of Article 8, per model, year and plant, not as an average. Second: they keep the underlying records as long as you need them; for due diligence records Article 48(3) requires ten years from the placing on the market of the last battery. Third: you retain an audit right, because it is you who carries the figure in the passport, not them. And fourth: what happens if their figure turns out to be wrong belongs settled before it happens.
Frequently Asked Questions
When do recycled content quotas become mandatory?
Minimum quotas apply from 18 August 2031 (Stage 1) and are tightened on 18 August 2036 (Stage 2). However, recycled content must be declared in the battery passport from February 2027, even before minimum quotas apply.
How is recycled content calculated?
The share is stated as a percentage of the total weight of the respective raw material in the battery. The Commission must set the method for calculating and verifying recycled content in a delegated act (Article 8(1), due by 18 August 2026). That act has not been adopted, so the documentation duty starts 24 months after it enters into force at the earliest, and not before 18 August 2028.
What's the difference between recovery rate and recycled content?
Recovery rate applies to recyclers (how much material is recovered from end-of-life batteries). Recycled content applies to manufacturers (how much recycled material is used in new batteries). Both values are directly connected.
Does the recycled content obligation also apply to lead-acid batteries?
Yes, lead actually has the highest recycled content quotas (85%), since lead recycling already has an established infrastructure achieving recovery rates above 99%.
