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.
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 August 18, 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 August 18, 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. Lead-acid batteries are subject to separate, even higher requirements.
Which Batteries Are Affected?
Recycled content obligations apply to the same battery categories as the battery passport:
- Electric vehicle batteries (EV): Traction batteries for e-cars, e-motorcycles
- Industrial batteries > 2 kWh: Stationary storage, UPS, energy storage systems
- LMT batteries: For e-bikes, e-scooters, and similar light means of transport
However, for LMT batteries, recycled content obligations only apply from 2033, not from 2031. 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: Verification 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:
From 2027
- Lithium: at least 50% recovery
- Cobalt, copper, lead, nickel: at least 90% recovery
From 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.
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.
Timeline: When Does What Apply?
- February 18, 2027: Battery passport becomes mandatory — recycled content must be declared (but no minimum quotas yet)
- August 18, 2028: CO₂ performance classes and limits
- August 18, 2031: Minimum quotas Stage 1 (16% cobalt, 6% lithium/nickel)
- 2033: Recycled content obligations also for LMT batteries
- August 18, 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.
Frequently Asked Questions
When do recycled content quotas become mandatory?
Minimum quotas apply from August 18, 2031 (Stage 1) and are tightened on August 18, 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 calculation method is defined by the EU regulation and must be verified by an accredited assessment body.
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%.