Circularity
How to Prove Recycled Content
How recycled content share is calculated and evidenced — mass balance, segregated and identity-preserved chains, pre- vs post-consumer, and certification schemes.
Recycled content is one of the fields ESPR delegated acts raise most often, and it is a mandatory public-tier field in the battery passport. The difficulty is that proving a material is recycled is far harder than calculating the share.
Pre- and post-consumer
| Type | Definition | Perceived value |
|---|---|---|
| Post-consumer | Material that reached a user and became waste | High |
| Pre-consumer | Production scrap and rejects | Lower (excluded by some schemes) |
Some regulations and brands accept only post-consumer content. Always state the distinction in your declaration.
Chain-of-custody models
- Identity preserved: the material is kept physically separate — strongest evidence, highest cost.
- Segregated: certified materials mix with each other but not with uncertified material.
- Mass balance: certified input is attributed to output through accounting. Common in chemicals and plastics.
- Book-and-claim credits: no physical link; generally not accepted in a DPP context.
What evidence to collect
- Supplier certificates (GRS, RCS or sector equivalents) and scope documents.
- Transaction certificates showing that a specific shipment was certified.
- Mass balance records: input/output accounting and the balancing period.
- Test reports: for some materials recycled content can be analytically verified.
See collecting data from suppliers and DPP clauses for supplier contracts.
How to carry it in the passport
Publishing a percentage alone is not enough. The field structure should include:
- The share (%) and which material it refers to
- Pre- or post-consumer designation
- The chain-of-custody model
- Certificate number, issuing body, validity
- The measurement or accounting period
See DPP data fields and circularity and recyclability.
The greenwashing risk
An unevidenced recycling claim is a direct risk under the Green Claims and Empowering Consumers Directives. With mass balance in particular, telling a consumer "this product contains recycled material" can be misleading. See the Green Claims Directive.
Further reading
Sector articles that go deeper on this topic:
- Proving Recycled Fibre: GRS, RCS and the DPP
- Recycled Content in Batteries (Article 8)
- Scrap Content and Alloy Proof for Aluminium
- Recycled Content in Electronics: The Horizontal Measure
- DPP for Plastic Raw Materials and Polymers
Frequently asked questions
Is mass balance accepted?
In many schemes yes, but the method must be declared explicitly. Some product groups may require physical traceability.
Which battery metals need a recycled content share?
Cobalt, lithium, nickel and lead are in the public tier. See Annex XIII data fields.
My supplier cannot provide a certificate. What now?
Do not publish an unevidenced share. Either mark the field as unknown or plan a move to a certified supplier.
