The European Commission is preparing a common methodology for measuring and verifying recycled cobalt, lithium, nickel and lead in batteries, bringing recycled-content claims into a more detailed compliance framework for manufacturers and importers.
A study published by the Commission’s Joint Research Centre (JRC) on 13 July 2026 sets out the technical basis for calculating, documenting and verifying recycled metals in batteries placed on the European Union market. Commissioned by DG Environment and DG GROW, the work will support a forthcoming delegated act under Article 8 of Regulation (EU) 2023/1542, the EU Batteries Regulation.
The methodology will determine what qualifies as recycled material, where recycled content is measured, how it can be allocated between products and what evidence companies must retain to substantiate their declarations. The framework will cover electric-vehicle batteries, light means of transport batteries, starting, lighting and ignition batteries, and industrial batteries above 2 kWh, including most commercial battery-energy-storage systems. The requirements will apply to batteries placed on the EU market regardless of whether they are manufactured inside the bloc or in countries including Germany, Hungary, China, South Korea and Serbia.
Recycled-content documentation begins from August 2028
From 18 August 2028, or 24 months after the delegated act enters into force, whichever is later, covered batteries containing cobalt, lead, lithium or nickel will have to include documentation specifying the amount of those metals recovered from battery-manufacturing waste or post-consumer waste. For cobalt, lithium and nickel, the calculation concerns their presence in active materials. For lead, the calculation covers the share of lead originating from waste.
The methodology therefore needs to accommodate different battery chemistries, manufacturing processes and material boundaries while preventing companies from selecting accounting methods that produce artificially high recycled-content percentages. Binding minimum recycled-content requirements begin in 2031. Batteries covered by the rules will have to contain at least 16% recycled cobalt, 85% recycled lead, 6% recycled lithium and 6% recycled nickel.
From 2036, the thresholds increase to 26% for cobalt, 85% for lead, 12% for lithium and 15% for nickel. These requirements make the accounting and verification of secondary material an important component of compliance alongside the physical availability of recycled metals.
Black mass creates complex traceability requirements
The calculation becomes more complicated once batteries enter industrial recycling chains. End-of-life batteries and manufacturing scrap are discharged, dismantled and mechanically processed into black mass, which can contain lithium, nickel, cobalt, manganese, graphite and other materials. Black mass may then move between countries, be blended with material from different sources and undergo hydrometallurgical or pyrometallurgical treatment. Recovered metals can ultimately become battery-grade salts, precursors or cathode active material.
At the cell-manufacturing stage, it may no longer be physically possible to connect a refined material to a particular waste battery. Cell plants also combine virgin and secondary inputs, carry inventories between accounting periods and manufacture several battery products using common production equipment. Some resulting materials remain within Article 8, while other outputs can be sold into applications outside the regulation.
JRC examines physical and mass-balance traceability
The JRC study focuses on chain of custody, linking recycled inputs and their environmental attributes with the batteries for which recycled-content claims are made. The report examines both physical traceability and more flexible mass-balance accounting, assessing the approaches against business continuity, material efficiency, climate impact, consumer confidence, verifiability and administrative costs.
A physically rigorous model follows recycled material through controlled production and blending. The resulting percentage remains closely associated with the material entering a particular process or product group. That approach provides stronger assurance that the claimed recycled material is connected to the relevant battery, but it can require separate storage, production scheduling and inventory controls. Global supply chains could also be required to segregate chemically identical materials or transport them over longer distances to maintain documentary links.
Mass-balance systems allow recycled and virgin materials to be combined while assigning the recycled attribute through an accounting system covering a defined plant, product group and balancing period.
The approach corresponds more closely with operating practices already used by chemical and battery-material producers. It can reduce production disruption and allow recycling material to be processed where recovery is technically and economically most efficient.
The principal verification challenge is preventing accounting flexibility from separating the recycled-content claim from the physical product. A production facility could theoretically allocate a high recycled-content percentage to a premium battery line while allocating little or none to other products from the same blended process, even though the overall accounting balance remains mathematically correct. The JRC has therefore developed calculation and verification blueprints for two traceability approaches, with the regulatory challenge centred on maintaining industrial flexibility while preventing double counting, artificial concentration of recycled attributes and unsupported transfers of credits between facilities or corporate entities.
Documentation will extend across the supply chain
Article 8 compliance will require substantially more than a certificate issued at the end of manufacturing. Companies will need auditable records covering the origin and classification of waste, material received, processing yields, quantities of recovered metals, transfers between facilities, inventory movements and allocation to battery models or product groups.
Records will also need to identify calculation periods, production losses, inventories carried between periods and recycled-content attributes transferred with intermediate materials. The requirements will also affect procurement contracts. A cell manufacturer cannot produce a defensible Article 8 declaration if a cathode-material supplier provides only a generic sustainability statement.
Supply agreements are therefore expected to require defined datasets, calculation methods, audit rights, document-retention requirements and liability provisions covering inaccurate recycled-content information.
Verified recycled material gains commercial importance
The emerging rules create a distinction between recycled material and verified recycled material.
Chemically identical materials such as nickel sulphate or lithium carbonate may have different commercial value depending on whether their waste origin, processing history and chain of custody can withstand an independent audit. Recyclers capable of supplying battery-grade materials together with complete supporting documentation will be positioned to enter long-term offtake arrangements with European cell manufacturers and automotive companies.
Existing European recycling facilities illustrate the infrastructure that will operate within this framework. BASF’s Schwarzheide black-mass plant in Germany, which entered commercial operation in June 2025, has capacity to process up to 15,000 tonnes of end-of-life lithium-ion batteries and production scrap annually, equivalent to approximately 40,000 electric-vehicle batteries.
The facility forms part of BASF’s wider battery-materials network, connecting black-mass processing, metal recovery and cathode-material production.
European recycling capacity expands across battery technologies
Mercedes-Benz’s Kuppenheim recycling plant has annual capacity of 2,500 tonnes and an expected recovery rate exceeding 96%. The recovered materials are intended to support production of more than 50,000 battery modules. Its integrated mechanical and hydrometallurgical process provides a structure in which physical material flows can be more directly aligned with recycled-content declarations.
In Norway, Hydrovolt’s Fredrikstad facility can process approximately 12,000 tonnes of battery packs per year, equivalent to around 25,000 electric-vehicle batteries. For facilities such as these, processing economics will increasingly include the ability to generate verified black mass and transferable chain-of-custody information alongside gate fees, recovery rates and processing costs.
EU remains dependent on imported batteries
The compliance framework is being introduced while Europe’s battery industry remains highly dependent on external supply. JRC data show that in 2024, more than 85% of batteries imported into the EU originated in China.
EU manufacturing capacity was sufficient to meet only 21.4% of estimated Union battery requirements for 2030, although this represented a 4.2 percentage-point improvement from the previous year. Under the Net-Zero Industry Act, the EU’s policy objective is to establish domestic manufacturing capacity capable of meeting at least 40% of annual deployment needs by 2030.
Recycling cannot immediately close the difference between European production and expected demand. Current electric-vehicle batteries will remain in service for years, and some battery packs will enter second-life applications before reaching recyclers. During the initial compliance period, manufacturing scrap could therefore represent a significant portion of available secondary feedstock. Post-consumer waste volumes are expected to increase as the European electric-vehicle fleet ages.
Battery chemistry affects recycling economics
The availability of feedstock will be important for the economics of the 2031 recycled-content requirements. A recycler may have nominal processing capacity without sufficient material to operate efficiently. Changes in battery chemistry can also alter the value recovered from each tonne of waste.
The increasing use of lithium iron phosphate (LFP) batteries reduces the cobalt and nickel content available from each tonne while maintaining the strategic importance of lithium recovery. Recycling facilities originally designed around revenue from nickel and cobalt may therefore require different gate fees, operating models or long-term supply contracts as LFP batteries account for larger shares of the waste stream.
The regulation will affect chemistries differently. Lead-acid batteries already operate within a mature recycling system, making the 85% recycled-lead requirement demanding but comparatively aligned with established industrial practice. Nickel-manganese-cobalt batteries face documentation requirements covering several metals. LFP batteries avoid the cobalt and nickel thresholds but remain subject to the recycled-lithium requirement and the same chain-of-custody requirements.
Battery storage projects face new procurement requirements
The effects will also extend to stationary energy storage before the formal recycled-content thresholds take effect. Utility-scale and commercial battery energy-storage systems generally use industrial batteries above the 2 kWh threshold. Developers, lenders and Owner’s Engineers will need battery supply contracts to address Article 8 documentation, access to supporting records and contractual remedies if supplied equipment does not meet applicable recycled-content requirements.
A battery system can remain technically operational even if its compliance documentation is incomplete. Incomplete evidence can affect delivery acceptance, market placement, replacement obligations, financing drawdowns and disputes over whether regulatory changes fall within supplier price and schedule responsibilities. Recycled-content compliance will therefore become an interface between technical specifications, supply-chain due diligence and project bankability.
Non-EU manufacturers face upstream evidence requirements
Battery manufacturers outside the EU will also need to meet the evidentiary requirements when their products are placed on the European market. An externally issued recycling certificate will not by itself be sufficient if the underlying methodology does not correspond to the delegated act.
Traceability may need to extend through recyclers, refiners, precursor producers, cathode-material suppliers, cell manufacturers and final assembly facilities. EU importers may consequently require contractual access to documentation held several tiers upstream, including records maintained outside the EU regulatory perimeter. For Serbia and the wider Western Balkans, the framework creates both compliance requirements and an industrial development opportunity for companies seeking access to European automotive and energy-storage supply chains.
Regional battery, component and raw-material projects will need EU-compatible material accounting from the development stage. The EU–Serbia strategic partnership on sustainable raw materials, battery value chains and electric vehicles provides a broader policy framework, while commercial participation will depend on plant-level data, verifiable material flows and documentation that can be provided to EU importers.
The JRC study leaves the balance between physical traceability and industrial flexibility as a central regulatory issue. A highly restrictive system could increase costs, fragment inventories and limit efficient recycling, while excessive flexibility could weaken the connection between the 2031 and 2036 recycled-content thresholds and the batteries placed on the European market. The forthcoming delegated methodology will determine which recycling investments produce not only recovered metals, but materials whose recycled content can be recognised through a legally defensible EU battery compliance system.
