Battery
Recycled Content in Batteries (Article 8)
Recycled content in batteries under Article 8: cobalt, lithium, nickel and lead documented from 2028, minimum shares from 2031 and 2036, and the passport field
The recycled content share in the public tier of the battery passport consists of four numbers everyone will see: cobalt, lithium, nickel and lead. Their source is Article 8 of the EU Battery Regulation (EU) 2023/1542, and the article runs on its own timetable independent of the passport: documentation first, then minimum shares in two steps.
Proving recycled content explains chain-of-custody models in general. Here we deal with the battery-specific scope, the percentages and the evidence chain.
Scope and timetable
| Step | Date | What is required |
|---|---|---|
| Documentation | 18 August 2028 | Share of cobalt, lithium, nickel and lead in active materials recovered from waste; per model and plant, per year |
| Minimum share, step 1 | 18 August 2031 | Cobalt 16%, lead 85%, lithium 6%, nickel 6% |
| Minimum share, step 2 | 18 August 2036 | Cobalt 26%, lead 85%, lithium 12%, nickel 15% |
The documentation accompanies the battery and expresses the share in the active materials; aluminium in the housing or copper in the cabling does not enter the calculation. The methodology comes from a delegated act; since the regulation ties the documentation date to that act's entry into force, the date can slip if the act is late. As of September 2026, treat the act as "expected".
The inclusion of SLI batteries matters for Türkiye's lead-acid manufacturers: they keep no passport, but from 2028 they prepare recycled content documentation for lead, and their 2027 QR codes open that information.
What "recovered from waste" means
The regulation defines the share through two waste sources: battery manufacturing waste (scrap arising in cell and pack production) and post-consumer waste (material recovered from end-of-life batteries). Unlike many general schemes, which exclude production scrap, the Battery Regulation explicitly counts battery manufacturing waste.
The open question is mass balance. When a refinery uses both primary and secondary inputs and declares a given percentage of its output as recycled, the conditions under which that share is accepted, how double counting is prevented and which evidence suffices are matters for the methodology act. Until it is published, ask your suppliers in writing which allocation method they use.
Where the evidence comes from
A pack maker cannot tell from its own records how much of the active material came from waste. The chain works like this: the recycler converts black mass into metal salts through hydrometallurgical processing; the precursor (pCAM) and cathode active material (CAM) producer blends those salts with primary material; the cell maker takes the cathode; the pack maker assembles the cells.
What to request from each link:
- From the recycler: a certificate showing the waste origin of the recovered material.
- From the CAM and pCAM producer: an annual, plant-level declaration of recycled input and the allocation method.
- From the cell maker: cobalt, lithium and nickel shares per cell model and the declarations they rest on.
- Independent verification: third-party verification of the declaration is part of conformity assessment.
Add these requests to your supplier data collection template and supplier contract today; when you discuss carbon data with the cell supplier, ask for the carbon footprint declaration at the same table.
How it appears in the passport
Annex XIII places the recycled content share of the four metals in the public tier. The declaration is per model, plant and year while the passport is per item; each battery's passport references the declaration of the year and plant it belongs to. A new year's value does not delete the old one; the passport gets a new version. For the field structure see battery passport Annex XIII.
Do not publish a share you cannot evidence: a public-tier percentage is also a marketing claim under the green claims rules, and "unknown" is safer than an unverifiable number.
Priorities for a Turkish manufacturer
- Determine which of your products fall under Article 8; a lead-acid SLI maker is outside the passport but inside the documentation duty.
- Ask cell and CAM suppliers for annual recycled input declarations; data collected before the act is published lets you evidence the previous year in 2028.
- Factor the rising minimum shares of 2031 and 2036 into supplier selection now.
For scope and responsibility see the battery passport guide; for the Türkiye-specific steps see the battery passport for Turkish manufacturers. A similar horizontal measure is being prepared for electronics; see recycled content in electronics.
Frequently asked questions
When is recycled content in batteries mandatory?
Documentation from 18 August 2028; minimum shares apply from 18 August 2031 and 18 August 2036. The documentation date can slip with the methodology delegated act.
Do LMT batteries need a recycled content share?
No. Article 8 is limited to EV, industrial above 2 kWh and SLI batteries; in an LMT passport the field is conditional.
What happens if the recycled content share is below the minimum?
Between 2028 and 2031 only documentation is required; a low share is not an infringement. From 18 August 2031 batteries that do not meet the minimum share cannot be placed on the market.
