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EU consultation

Methodology for calculation and verification of recycled content in batteries

61 submissions from 60 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.

The Commission received 70 submissions on this file. Shown here: the 61 from organizations. Not shown: 5 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 4 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →

Who showed up

47 submissions from industry (companies and their trade associations) against 8 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 5.9 industry submissions for every one from civil society.

Industry 47Civil society 8Public authorities, academia, other 6

Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.

What the room declares

27 of 60
in the EU Register
142
full-time lobbying staff
€11.9M+
declared costs a year
95
EP accreditations declared

Self-declared to the EU Transparency Register (snapshot 14 Oct 2026). The cost figure sums band floors, so the true total is higher.

The file, right now

The consultation closed on 9 Sept 2026; it ran from 12 Aug 2026.

Policy area
Sustainability (DG ENV)
Where it stands
Awaiting adoption
Adoption expected
30 Sept 2026

How it got here

  1. Reg del draft9 Sept 2026

Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Reg del.

Showing 25 of 61 submissions.

IE

IDEE ECONOMICHE

· · filed 9 Sept 2026 · source

Under the Batteries Regulation, several categories of batteries will have to contain a certain percentage of recycled metals to be allowed to be placed on the EU market. In particular, the Regulation sets recycled content targets for lithium, cobalt, nickel and lead. Two sets of targets will apply from 2031 and 2036, respectively.

Filed in Italian · English published by the European Commission

LinkedInX
DE

DigitalTrade4.EU

· · filed 9 Sept 2026 · source

PDF

We welcome the Commissions approach to recycled-content traceability and verification under Regulation (EU) 2023/1542. The draft already establishes a distributed chain-of-custody model in which supply-chain actors retain traceability data in their own systems, while relevant data are exchanged across consecutive actors and verified by notified bodies.

LinkedInX
JF

Jervois Finland Oy

· · filed 9 Sept 2026 · source

In Article 8, we propose a clear definition of post consumer waste. Post-consumer waste should include all recycled cobalt, regardless of whether it comes from batteries, hard metals, catalysts, superalloys, electronics or other waste streams. Post-consumer waste should count towards Article 8 recycled content targets.

LinkedInX
R

RECHARGE

· · filed 9 Sept 2026 · source

PDF

RECHARGE provides with this paper industry feedback and recommendations on certain key elements of the proposed rules. The proposal contains a number of important and pragmatic choices, including the recognition of plant-level mass balance, reconciliation mechanisms and the possibility of contractual allocation arrangements through extended toll treatment and multi-party contracts.

LinkedInX
EC

Economic Chamber of Non-Ferrous Metals and Recycling /IGMNiR/

· · filed 9 Sept 2026 · source

PDF

IGMNiR position for the European Commission's public consultation on the draft Delegated Regulation establishing the methodology for the calculation and verification of recycled content in certain batteries (Initiative 14858; draft ref.

LinkedInX
NI

Nickel Institute

· · filed 9 Sept 2026 · source

PDF

The Nickel Institute provides feedback on the European Commission's draft regulation regarding the methodology for calculating and verifying recycled content in batteries, focusing on cobalt, nickel, lithium, and lead. The comments aim to ensure that the regulation is practical and supportive of existing recycling efforts without imposing unnecessary bureaucracy.

LinkedInX
FB

Fortum Battery Recycling Oy

· · filed 9 Sept 2026 · source

Fortum Battery Recycling welcomes the draft Delegated Act and the rules for the calculation and verification of recycled content in batteries. Clear and harmonised EU rules play an important role in stimulating demand for recycled materials, strengthening the market for secondary raw materials, and enabling credible recycled content claims.

LinkedInX
HG

Heyi Green Foundation

· · filed 9 Sept 2026 · source

PDF

We support a harmonised, verifiable Article 8 methodology. Existing controls do not fully close claim lifecycles or reconcile the drafts time rules. We recommend four changes. 1. Delete the 1.3 correction factor. Article 8(1) concerns recovered materials present in active materials or the battery.

LinkedInX
TM

Toyota Motor Europe

· · filed 9 Sept 2026 · source

PDF

Toyota Motor Europe (TME) supports the objectives of Regulation (EU) 2023/1542 and the development of a harmonized methodology for calculating and verifying recycled content in batteries. Please find attached TME opinion regarding the draft delegated regulation.

LinkedInX
RE

Recycling Europe

· · filed 9 Sept 2026 · source

PDF

The rules for the calculation and verification of recycled content in batteries can play in important role in stimulating demand for recycled materials sourced within the EU, and strengthening the EU market for recycled materials, while enabling brands to make credible recycled content claims.

LinkedInX
CM

Circular Materials

· · filed 9 Sept 2026 · source

Circular Materials welcomes the proposed calculation and verification of recycled content in batteries. We recognise that the scope of eligible recycled nickel derives from Art. 8(2) of Regulation (EU) 2023/1542 and is therefore not introduced by the present Delegated Regulation.

LinkedInX
EA
PDF

EUROBAT welcomes the opportunity to comment on the draft delegated act adopted pursuant to Article 8 of Regulation (EU) 2023/1542. We appreciate the Commission's work and note that the proposed methodology is broadly aligned with the principles discussed during the JRC consultation, particularly as regards mass-balance accounting and documentation-based traceability. EUROBATs comments are targeted and constructive.

LinkedInX
BS

Business & Science Poland (BSP)

· · filed 9 Sept 2026 · source

PDF

Business & Science Poland (BSP) welcomes the European Commission's objective of increasing the use of secondary raw materials in batteries and strengthening the resilience of the European battery value chain. The methodology should combine environmental integrity, industrial feasibility and effective incentives for investment in European recycling and recovery capacity.

LinkedInX
NA

Nissan Automotive Europe

· · filed 9 Sept 2026 · source

PDF

Please find attached an interim submission from Nissan on limited elements of the draft regulation because of their centrality to the wider success of any efforts to establish and maintain a domestic battery recycling supply chain within the EU. Nissan is an active member of the European Automobile Manufacturers Association (ACEA).

LinkedInX
EM

E-Mobility Europe

· · filed 9 Sept 2026 · source

PDF

E-Mobility Europe welcomes the Commissions draft Delegated Act setting out the methodology for calculating and verifying recycled content in batteries under Article 8 of the Batteries Regulation. We broadly support the proposed approach and consider that the methodology provides a workable framework for establishing recycled content claims through plant-level mass balance, supply-chain traceability and appropriate…

LinkedInX
VC

Volvo Cars

· · filed 9 Sept 2026 · source

Volvo Cars welcomes the opportunity offered to review the proposed methodology for the calculation and verification of recycled content in batteries. We support the proposed approach to apply an (up to) yearly average of recycled content in a specific plant, with the possibility to allocate a specific share, if there are contractual agreements of the set-up with recycled content loops in place.

LinkedInX
EM

European Metals

· · filed 9 Sept 2026 · source

PDF

While recycled content (ReCo) requirements are not the best tool to boost demand for recycled metals, in the context of the proposed measures, European Metals considers the proposed delegated act and annex on the methodology for the calculation of ReCo in batteries strikes a correct balance between physical plausibility, traceability and practical implementation.

LinkedInX
FM

Finnish Minerals Group

· · filed 9 Sept 2026 · source

PDF

Summary of FMGs position Finnish Minerals Group (FMG) welcomes the draft Delegated Act and its aim to secure the availability of recycled lithium, nickel and cobalt inside the Union. However, as stated in the draft, the availability of recycled content for these metals is, and will remain, insufficient to meet the obligations of Article 8 on the timelines set out in Regulation (EU) 2023/1542.

LinkedInX
EO

E.ON SE

· · filed 9 Sept 2026 · source

E.ON appreciates the opportunity to provide feedback on the Draft Delegated Act on calculation and verification of recycled content in batteries, an important piece of legislation to ensure circularity and sustainability in batteries, hence important for electrification. The proposal correctly places responsibility for calculating and verifying recycled content with the battery manufacturer.

LinkedInX
IM

Institut Mobilités en Transition (IMT-Iddri)

· · filed 9 Sept 2026 · source

PDF

IMT welcomes the draft of the Delegated Act setting the methodology for calculating and verifying recycled content rates, as it represents a critical step towards the transition to a circular European battery value chain.

LinkedInX
SB

Swiss Battery Technology Center

· · filed 9 Sept 2026 · source

PDF

Thank you for the opportunity to provide feedback on the proposed methodology for the calculation and verification of recycled content in batteries. Overall, the methodology provides an important framework for improving the traceability and consistent accounting of recycled materials within the battery value chain.

LinkedInX
AA

AURUBIS AG

· · filed 9 Sept 2026 · source

Aurubis supports the development of a robust, harmonised methodology for calculating and verifying recycled content in batteries. Our main comments relate to two aspects: 1. Limiting recycled content of lead to waste. The current definition of recycled content for lead restricted to materials recovered from waste does not fully reflect how modern industrial circularity operates.

LinkedInX
EE

EURAMET e.V.

· · filed 9 Sept 2026 · source

EURAMET, the European Association of National Metrology Institutes, welcomes the draft Delegated Regulation. We support a competitive, circular and resilient European battery value chain and recommend clearer requirements for the quality of the measurement data underpinning the proposed methodology.

LinkedInX
CG

cylib GmbH

· · filed 9 Sept 2026 · source

PDF

The European Commissions draft delegated act will determine how recycled content is calculated, verified and documented in batteries. For a recycling company, these rules will influence whether material from black mass and other battery waste streams is recognized fairly, whether hydrometallurgical processes can operate at scale, and whether the EU framework gives investors a credible signal to build European…

LinkedInX
N

Nyrstar

· · filed 9 Sept 2026 · source

1. Definition of recycled content: Inclusion of by-products in the definition of "recycled content": A substantial portion of Europes circular material flow relies on the recovery and reuse of industrial by-products. These by-products, generated during industrial processes (such as zinc production), are directly or indirectly utilized in other production cycles without ever being classified as waste.

LinkedInX
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Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.