How do I demonstrate the share of recycled cobalt, lithium, nickel and lead?
Demonstration is carried out by means of a calculation per battery model and factory
The share of recycled cobalt, lithium, nickel and lead is demonstrated by means of a calculation of the quantity of that material which comes from production waste or from used material (post-consumer waste), expressed as a percentage of the total cobalt, lithium, nickel or lead contained in the active materials of the battery. This calculation is carried out per battery model and per factory, and is repeated per year, so that the figure represents an average of the production in that period and not of a single battery. The result belongs in the technical documentation of the battery and, once the digital battery passport for the battery type in question is mandatory, also in that passport itself — so that an importer, dealer or end-user can find the content without having to contact the manufacturer separately.
For which batteries and materials this applies
This obligation applies to industrial batteries (with the exception of batteries that are stored externally only without being located in the device itself), batteries for electric vehicles and starting, lighting and ignition batteries (SLI batteries), insofar as these contain cobalt, lead, lithium or nickel in their active materials. Batteries for light means of transport, such as the battery of an e-bike or a shared scooter, do not fall under this — for that category, Article 8 does not describe any obligation regarding recycled material. The obligation also applies only to the four metals mentioned; for other materials in the battery, such as copper or graphite, this article does not prescribe a share of recycled material. Anyone in doubt as to whether a specific battery type falls under the definitions in the regulation will find the classification in the regulation itself.
When the obligation comes into force
Article 8 operates with an increasing series of obligations. From 18 August 2028, the technical documentation must state the content of recycled cobalt, lead, lithium and nickel — this is initially an information obligation, without a minimum percentage being prescribed at that point. From 18 August 2031, a minimum share is added: 16% for cobalt, 85% for lead, 6% for lithium and 6% for nickel. From 18 August 2036, those minimum percentages continue to increase, to 26% for cobalt, 85% for lead, 12% for lithium and 15% for nickel. Until 18 August 2028, Article 8 does not yet describe any obligation regarding this data; nothing, however, prevents a manufacturer from voluntarily disclosing the content at an earlier date.
How this is handled in practice
For an importer or dealer supplying the data for the product passport, this starts with the manufacturer: the origin and share of recycled cobalt, lead, lithium and nickel are namely determined at the level of the battery factory, not at the level of the importer or seller. The first step is to check whether the manufacturer is already keeping these data and can provide them, for example via a declaration or certificate per battery model and production location. The second step is to verify that the supplied figure corresponds to the correct period: this is an average per year per factory, so a single measurement or sample is not in itself sufficient. The third step is to have this data included when compiling the passport, so that it ends up in the correct place alongside the data from Annex XIII. For batteries that are already on the market and will still be relevant after 2028, it is practical to arrange this supply with the manufacturer now, so that the documentation does not have to be supplemented later.
The basis: Article 8 and Annex XIII
This follows from Article 8 of Regulation (EU) 2023/1542 (Battery Regulation), which regulates the recycled content: which batteries and materials are concerned, how the share per battery model and factory is calculated, and which percentages and dates apply. Which data on this must specifically appear in the digital battery passport is set out in Annex XIII to the same regulation — the annex containing the complete list of mandatory passport data.
Anyone already collecting data for a battery falling under Article 8 is well advised to ask the manufacturer for the share of recycled cobalt, lead, lithium and nickel per battery model and production location, and to keep that data together with the rest of the technical documentation so it is ready when the obligation for the battery type in question comes into force.
What this is based on
- Regulation (EU) 2023/1542, Article 8 (recycled content)
- Regulation (EU) 2023/1542, Annex XIII (data in the battery passport)
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
What is expected of you
State the share of recycled cobalt, lithium, nickel and lead
Article 8 of Regulation (EU) 2023/1542 (battery regulation) requires disclosure of the percentage of recycled material derived from production and consumption waste, per battery or per battery model, for these four substances. For a company with 10 to 100 employees, this means in practice that a figure per substance must be available, not merely a qualitative claim such as "contains recycled material". Anyone who imports batteries or assembles them from cells supplied by a supplier depends on this figure from what that supplier can provide — and that information must be documented before the passport is compiled.
Keep the figure traceable to a source
A percentage alone is insufficient if it is not clear where it comes from. The data that must appear in the battery passport are described in Annex XIII of Regulation (EU) 2023/1542 (battery regulation), and the share of recycled material is one of the items alongside other material data. This immediately raises the question of how this relates to the data on the materials in a battery that must be specified precisely — the share of recycled material is an addition to the material composition, not a replacement for it. Both pieces of information must exist side by side in the passport.
Make the distinction between production waste and consumption waste
The regulation refers to recycled material from production waste and from consumption waste (post-consumer recyclate). This distinction is relevant because it indicates something about the origin of the material: residues from a production process are different from material recovered from discarded batteries. For a company that purchases cells from different suppliers, this may mean that the share per supplier and per delivery can vary, and that an average figure is not usable without explanation for one specific battery model.
Keep the figure current per model or production batch
Because the share of recycled material depends on the production in question, it is not fixed for the entire lifespan of a product line. This raises the question how often the data in the battery passport must be updated — a change in the supply chain or in the recycling percentage of a supplier may have consequences for the figure included in an ongoing or new passport.
Where things go wrong in practice
An estimate is presented as a hard figure. An importer receives a general marketing claim from the cell manufacturer ("30% recycled material") without underlying specification per substance, and takes that figure over as if it were a measured value for cobalt, lithium, nickel and lead individually.
The figure is not broken down per substance. One percentage is stated for "recycled material" in general, while the obligation requires a share per individual substance — cobalt, lithium, nickel and lead each need their own figure.
The origin of the figure can no longer be traced. Half a year after compiling the passport, a question is raised about what the percentage was based on, and no one in the company can point to which document, which supplier declaration or which calculation was at the basis.
An average figure is applied to an individual battery model. A trader uses a sector average or a figure from a comparable model, because the company's own supplier cannot provide an exact percentage for the specific batch.
Changes at the supplier are not implemented in existing passports. The supply chain changes — a new raw material source, a different recycling percentage — but the already published passport continues to show the old figure.
What you can record
- A supplier declaration per substance, in which the cell manufacturer or raw material supplier specifies the share of recycled material for cobalt, lithium, nickel and lead separately, including an indication of whether it concerns production waste or waste from the use phase.
- A document that marks the difference between estimate and measured value, so that during an inspection it is clear which figure is based on which basis and what uncertainty is associated with it.
- A link between the percentage and a specific battery model or production batch, so that a figure is not isolated from the batch to which it applies.
- An overview of when a supplier last submitted a figure, as a basis for assessing whether an update is necessary upon new delivery or contract modification.
- A file in which the share of recycled material is linked to the broader material composition, so that these two data — which are separate but interrelated in Annex XIII of Regulation (EU) 2023/1542 (battery regulation) — do not end up isolated from each other in different systems.
- A template for the supplier questionnaire, to ask the same questions of each new supplier or cell batch about origin, measurement method and percentage, so that the data remain mutually comparable.
Those who wonder how this percentage relates to other mandatory information in the passport, such as the performance and sustainability data that are mandatory or the broader question which data exactly must be included in the battery passport, would be well advised not to treat the share of recycled material as an isolated figure, but as part of a file that covers the entire material origin of the battery.
This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.