EU Consults on Recycled Content Calculation and Verification for Batteries
Reference source : European Commission
On 12 August 2026, the European Commission opened a consultation on a draft delegated regulation that would establish a methodology for calculating and verifying the recycled content in certain batteries under the EU Batteries Regulation (EU) 2023/1542. The proposal also sets out the format for documenting recycled content.
The methodology covers cobalt, lithium, nickel and lead, and would apply to industrial batteries with a capacity of more than 2 kWh, except those with only external storage, as well as electric vehicle (EV), starting, lighting and ignition (SLI), and light means of transport (LMT) batteries.
Stakeholders can submit feedback on the proposal until 9 September 2026. The Commission plans to adopt the delegated regulation in the third quarter of 2026.
Proposed Calculation and Traceability Rules
Under the draft methodology, battery manufacturers would calculate the recycled content of cobalt, lithium, nickel and lead for each battery model, per year and per manufacturing plant. For cobalt, lithium and nickel, the recycled content would be based on material recovered from battery manufacturing waste or post-consumer waste, while recycled lead may originate from waste more generally.
The methodology uses a plant-level mass-balance approach, supported by a traceability system covering the relevant supply chain. Manufacturers would be required to collect information from preceding supply-chain actors, beginning with suppliers of secondary materials. Each actor would maintain their own traceability data and pass relevant information downstream.
Accounting periods could be selected by Manufacturers and other supply-chain actors but these could not exceed the 12-month documentation period. A rolling-average approach would be used to determine the recycled content assigned to output fractions during the accounting period.
1.3 Correction Factor for Materials Recycled in the EU
A notable element of the proposal is the temporary incentive for certain materials recycled in the EU. Until 31 December 2036, qualifying recycled lithium, nickel and cobalt originating from EU recycling operations could be assigned a correction factor of 1.3 when calculating the recycled content. This factor would not apply to lead.
In practice, this correction factor provides a 30% uplift to the amount of qualifying recycled material for calculation purposes. For example, 100 kg of qualifying recycled material would be treated as 130 kg when calculating recycled content. While this does not increase the physical amount of recycled material in the battery, it does give qualifying EU-recycled material additional weight in determining compliance with recycled-content requirements.
The correction factor can only be applied once in the value chain and the calculated recycled content cannot exceed 100%. Where recycling takes place in several steps at different facilities, all of these steps would have to be carried out in the EU. Therefore, the production of black mass in the EU alone would not qualify if its further recycling takes place outside the EU.
According to the Commission, this temporary measure is intended to address the risk of insufficient availability of recycled battery materials in the EU, as well as strengthening the resilience and security of the EU battery value chain.
Documentation and Verification
The draft also introduces detailed data and documentation requirements across the supply chain. Relevant operators would have to maintain traceability information, including evidence concerning the origin and movement of recycled materials. Digital records covering the required accounting periods must be kept for at least 10 years, and recycled-content calculations must be performed using digital calculation tools such as spreadsheets or accounting software.
Battery manufacturers would prepare or update a recycled-content study for each documentation year. Notified bodies would assess the documented recycled content verifying that the underlying information is reliable and traceable, and that the calculations have been performed correctly. Verification could extend to information and documentation held by operators at different stages of the battery value chain.
Next Steps
The Commission is accepting feedback on the draft delegated regulation until 9 September 2026. Following the consultation and finalisation of the methodology, Commission adoption is planned for the third quarter of 2026.