Methodology for calculation and verification of recycled content in batteries

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

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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).

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…

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.

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.

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.

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.

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.

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.

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.

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.

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…

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.

Energy Storage Europe welcomes the draft delegated regulation. It provides workable methodological flexibility while preserving traceability integrity. We support its overall direction and offer the following targeted comments. 1.

MOL Group’s key comments on the calculation and verification of recycled content in batteries MOL Group welcomes the European Commission's initiative to establish a harmonized methodology for the calculation and verification of recycled content in batteries under the EU Batteries Regulation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Orano would like to thank the European Commission for preparing this delegated act. Article 8 of the Batteries Regulation and its delegated act are essential to accelerate circularity within the European battery value chain and strengthen the use of secondary raw materials.

EBRA welcomes the opportunity to provide feedback on the draft Delegated Act establishing the methodology for the calculation and verification of recycled content in batteries. Please find attached EBRA's detailed position paper, which outlines our support for the objectives of the proposal together with recommendations aimed at strengthening the development of a competitive and sustainable European battery…

Position of the Manufacturers Association of Israel Draft Commission Delegated Regulation Supplementing Regulation (EU) 2023/1542 as regards the methodology for the calculation and verification of recycled content in batteries Ensuring fair recognition of equivalent third-country recycling within the European battery value chain The Manufacturers Association of Israel (MAI) supports the objectives of Regulation (EU)…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As an electric vehicle manufacturer based in Türkiye sourcing finished traction batteries from independent battery manufacturers, we support the establishment of a harmonised recycled-content methodology. However, the responsibilities of downstream vehicle manufacturers should be clearly defined.

ACEM welcomes the possibility of submitting written feedback regarding the public consultation, due on the 9th of September, on Article 8 of the Batteries Regulation (EU) 2023/1542. The motorcycle industry remains available to further cooperate and provide more clarifications. Our full feedback can be found in the attachment.

The vast majority of Ni-containing battery recycling processes produce nickel sulfate and cobalt sulfate, raw materials used by most CAM manufacturers to supply their customers producing NMC and NCA lithium-ion batteries. However, if Lithium-ion batteries are a key technology today, it is a fact that they do not address every industrial requirement.

T&E welcomes the draft delegated act on the calculation and verification of recycled content in batteries, as a key step towards driving a circular battery value chain in Europe. At this stage of market development, we consider the chain of custody model of mass balance with volume reconciliation and credit allocation to be acceptable.

The global lead recycling rate is approximately 66% (estimated by CRU, a market research firm). In addition, battery manufacturers in Japan have established schemes for collecting used batteries and implemented measures to prevent illegal disposal. Against the backdrop of rising lead prices, the outflow of used batteries overseas has become an issue in Japan.

The European Cycling Industries believes in the important role played by batteries in the proliferation of sustainable mobility. As more Europeans buy E-Bikes, having the right battery configuration becomes important to ensure the sustainability of the technology behind the transport method. ECI believes that LMTs face several challenges in implementing the Commission's proposal for recycled content in batteries.

Feedback of MILI Recycling for Israel Ltd. on Section 2.2.5 of the Annex (correction factor for recycling within the Union). Full paper attached. MILI is building Israel's first recycling plant for lithium-ion batteries from vehicles (Neot Hovav, from Q1 2027), designed to European standards and integrated into the Union value chain: pre-treatment in Israel, close to the source of the waste, and sale of the black…

AEM's comments support the European Commission's objective of advancing a circular battery economy while emphasizing the importance of practical and transparent implementation of the recycled-content requirements under Regulation (EU) 2023/1542.

The BMW Group welcomes the European Commissions Draft Delegated Act for the recycled content calculation and verification rules in the context of the EU Battery Regulation (EU 2023/1542). Strengthening the circular economy and therefore reducing environmental impacts through involving recycled content is an essential part of BMW Groups sustainability strategy.

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.

As a cell/module manufacturer, we would welcome further clarification regarding the practical implementation of the proposed credit-allocation mechanism for European cell and module manufacturers. It is important to distinguish between cell/module manufacturers and battery manufacturers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Garden Machinery Federation (EGMF) represents large and small manufacturers of garden, landscaping, forestry, and lawn maintenance equipment through its 31 full members, 7 national associations, and 6 associate members. It is registered in Europe since 1977.

UL Solutions welcomes the European Commission's efforts to establish a harmonized methodology for the calculation and verification of recycled content in batteries under Regulation (EU) 2023/1542. A robust and transparent methodology is essential to support the implementation of recycled-content requirements while ensuring consistency across the battery value chain.

Bosch strongly supports the transition to a circular economy and particularly welcomes the European Commissions decision to adopt a flexible, credit-based mass balance system on an operational level for recycled content. Discarding impractical physical segregation models is a crucial step to safeguard the operational viability of continuous industrial manufacturing.

ECOS welcomes the opportunity to provide feedback on the draft delegated regulation establishing the methodology for the calculation and verification of cobalt, nickel, lithium and lead recycled content in certain batteries, and the format for the documentation of such recycled content under Article 8.1 of the Battery Regulation.

Title: Correction Factor Exemption for Lead (Section 2.2.5) Page No: 4-5 Comment/Opinion: The draft text defines an incentive (1.3 correction factor) valid until 31 December 2036 for cobalt, nickel, and lithium recycled within the EU borders, but completely excludes lead from this incentive.

At the Japan-EU Summit held in July last year, the leaders, under the EU-Japan Competitiveness Alliance, agreed to work together to uphold and strengthen a free, fair, and rules-based economic order that is stable and predictable, including by preserving the multilateral trading system with the WTO at its core.

We welcome the opportunity to comment on draft act of the delegated regulation on the methodology for the calculation and verification of cobalt, nickel, lithium and lead recycled content in certain batteries, and the format for the documentation of such recycled content as mandated by Article 8 (1) of Regulation (EU) 2023/1542.

The Battery Association for Supply Chain (BASC) is Japans first industry organization dedicated to the battery supply chain, established in April 2021. As of September 2026, BASC has 253 member companies, including battery manufacturers, battery material and component suppliers, trading companies engaged in the procurement of critical minerals, recyclers, banks, IT companies, and automotive manufacturers.

Batteries that have become obsolete models and are supplied only as service / replacement parts should be excluded from the scope. (Rationale) Even though the volumes involved in supplying customers with service parts are extremely small, the annual certification work must still be carried out, which we believe places a significant burden not only on the shipping manufacturer but also on the European certification…

EICBI supports the proposal's objective of promoting circularity, resource efficiency and greater use of secondary raw materials. At the same time, the verification framework should remain proportionate, transparent and practical for businesses across international battery supply chains, particularly SMEs and suppliers outside the EU.

Lead Exemption from the "Correction Factor" (Section 2.2.5) The draft text introduces an incentive mechanism (a 1.3 correction factor) for cobalt, nickel, and lithium recycled within the EU until 31 December 2036, while excluding lead entirely from its scope.

Inclusion of UK, Switzerland, and Norway : LIBREC AG operates a mechanical pre-treatment facility for the recycling of Lithium-Ion Battery waste and Lithium-Ion Battery production scraps in Switzerland. As Switzerland is surrounded by EU member states, the majority of the feedstock of LIBREC originates from the EU.

Umicore welcomes the European Commission's draft Delegated Act on the calculation and verification of recycled content in batteries. The proposal contains a number of pragmatic choices that reflect the realities of industrial battery recycling and materials processing, including plant-level mass balance, reconciliation mechanisms and contractual allocation arrangements.

We believe that plant-level mass balance with volume reconciliation can help maintain integrity, provided that credit allocation is limited to specific contractual arrangements, such as tolling, directed-buy agreements, or take-back mechanisms.

Lubin,3 September 2026 KGHM comments on the Delegated Act on calculation and verification of recycled content in batteries 1. Recognition of industrial by-products in the recycled content methodology KGHM supports the objective of increasing the use of recycled materials in batteries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir or Madam, We welcome the European Commissions draft Delegated Regulation supplementing Regulation (EU) 2023/1542 and establishing a methodology for the calculation and verification of recycled cobalt, nickel, lithium and lead content in batteries.

The International Lead Association (ILA) supports the development of a robust, harmonised methodology for calculating and verifying recycled content in batteries. Detailed comments are included in the attached file. Our main observations relate to: - Linking battery recycled content solely to waste and failing to recognise the important role industrial by-products play in reducing use of virgin material.

To support consistent implementation by parties such as manufacturers, supply-chain actors, notified bodies, and market-surveillance authorities, we advise the European Commission to consider calling for standardisation work (through CEN/CENELEC) in support of Article 8 of Regulation (EU) 2023/1542.

As a manufacturer of recycling machinery and process systems, we see one issue repeatedly emerging as one of the biggest challenges in battery recycling: **the lack of accurate and transparent information about the composition of the batteries entering the recycling process. Battery recycling is not a simple mechanical process.

1.If battery plant produce battery products which will be placed on EU market every day in the documentation year, does that mean the rolling window need to be changed for every day, for example, 3.1-6.1 for batch produced on 6.1, 3.2-6.2 for batch produced on 6.2 (assuming accounting period is 3 months)? That's really too much workload, not all company can build online platform to automatically calculate Reco.