Recycled Content Declaration for Batteries: What It Means for Importers

Another field the battery passport carries is a recycled content declaration: how much of certain materials in the battery came from recovered sources rather than newly mined ones. For importers, this is a supplier-sourced figure, so understanding it early makes the data request cleaner. This guide covers the essentials.

What the recycled content declaration is

The EU Battery Regulation requires certain batteries to declare the share of recycled content in specific metals recovered from waste, expressed as a percentage of the material present in the battery. The point is to give a verifiable measure of how much recovered material a battery contains, which supports the regulation's wider recycling goals.

Like the carbon footprint, this is a declared, method-based value rather than an estimate, and it feeds the passport as one of the Annex XIII data groups. See Annex XIII explained.

Which materials it covers

The declaration concerns recovered content in four metals, not the whole battery mass: cobalt, lead, lithium and nickel (Art. 8 of Regulation (EU) 2023/1542). It is phased in two ways. First comes documentation of the recycled content actually present; later come minimum shares that rise over time. For industrial batteries over 2 kWh, electric vehicle batteries and SLI batteries, documentation starts from 18 August 2028 (tied to a Commission methodology act, so the effective date can move), with minimum shares from 18 August 2031 (cobalt 16%, lead 85%, lithium 6%, nickel 6%) and higher shares from 18 August 2036 (cobalt 26%, lead 85%, lithium 12%, nickel 15%). LMT batteries, the e-bike and e-scooter category, come in later: documentation from 18 August 2033 and the shares from the 2036 tier. The calculation method itself is to be set by a Commission delegated act, which the regulation required by 18 August 2026.

Why it is your supplier's data

Recycled content depends on the materials that went into the cells and how they were sourced and documented. That is manufacturing information, so it originates with the manufacturer. As the operator placing the battery on the market you are responsible for the declaration being in the passport, but the figure and its evidence come from your supplier.

That makes it another reason to raise the passport during purchasing rather than after. See what your supplier must send you, and for the closely related environmental field, the carbon footprint declaration.

What to ask your supplier for

• The declared recycled content for the relevant metals, for the specific model.
• The calculation and verification basis, so the figure is defensible.
• The supporting documentation that evidences it.

How it fits the timeline

Because these figures are upstream and evidence-backed, and the targets ratchet up over time, treat recycled content as a long-lead item: request it well before you need the passport live, and re-check the figure as the higher shares approach.

In short

The recycled content declaration states the share of recovered material in four metals, cobalt, lead, lithium and nickel, as a defined and evidenced figure the passport carries under Annex XIII. It comes from your manufacturer, and it phases in over time (documentation first, then rising minimum shares, with LMT batteries brought in later). Request the figure, its basis and its documentation early.