EU Proposes Rules for Calculating Recycled Content in Batteries

The European Commission has proposed rules for calculating and verifying recycled cobalt, lithium, nickel and lead in batteries. The draft also sets out the documentation manufacturers would need to support their recycled-content figures.

The proposal follows Article 8 of the EU Batteries Regulation, which introduces recycled-content disclosure requirements and, at later dates, minimum recycled-content shares. The new methodology would give manufacturers a common basis for calculating those shares and demonstrating compliance.

It covers industrial batteries above 2 kWh, except those with exclusively external storage, as well as electric vehicle, starting, lighting and ignition (SLI), and light means of transport (LMT) batteries.

Traceability from recycling to battery production

Under the draft, recycled-content claims would need to be supported by records linking waste entering a recycling plant to the recovered material used in a battery. Calculations would be made for each battery model, per year and per manufacturing plant.

Manufacturers would therefore need information from recyclers and material suppliers, not just a percentage stated on a supplier declaration. The supporting records would have to allow the origin and movement of the recovered material to be checked.

The distinction between recycled material and production scrap is also important. Material that can be reclaimed within the same process that generated it does not count towards the recycled-content calculation envisaged by the Batteries Regulation.

Status of the proposal

The draft was notified to the WTO on 14 August 2026, with comments due by 13 October 2026. The notification indicated October 2026 as the proposed adoption date, but that timetable is not confirmation of adoption.

The act would enter into force 20 days after publication in the Official Journal. This should not be confused with the separate dates for recycled-content disclosure and minimum shares under Article 8.

For battery manufacturers and their suppliers, the proposal highlights the need to retain evidence behind recycled-content claims. Companies will need to establish which materials qualify and whether their supplier records can support the calculation.

Sources: European Commission – WTO notification G/TBT/N/EU/1233 ; Draft calculation and verification methodology ; EU Batteries Regulation, Article 8 .