EU study sets out battery recycling tracking rules

The European Commission's Joint Research Center has published a study outlining how battery makers could demonstrate they are using recycled cobalt, lithium, nickel and lead, with future EU compliance expected to rely on documentation, supply-chain data and audits rather than laboratory testing of finished batteries.

As batteries reach the end of their life cycle, production offcuts or used batteries can be collected, dismantled, and shredded to produce a substance known as black mass. This black mass can then be processed to extract essential metals. Recycling black mass is increasingly vital as a supplement to the supply of virgin materials and to reduce the carbon footprint of the battery supply chain.

Published on July 13, the JRC study was prepared to support the European Commission's delegated act under Article 8 of the EU Batteries Regulation. The delegated act, expected by August 2026, will establish harmonized rules for calculating and verifying recycled content in batteries placed on the EU market.

Article 8 requires certain industrial batteries above 2 kWh, EV batteries and starting, lighting and ignition batteries to include documentation showing the share of cobalt, lithium and nickel in active materials recovered from manufacturing waste or post-consumer waste. It also requires documentation of the share of lead in the battery recovered from waste.

The regulation sets minimum recycled-content targets from 2031 of 16% for cobalt, 6% for lithium, 6% for nickel and 85% for lead. These targets rise to 26% for cobalt, 12% for lithium, 15% for nickel, and 85% for lead in 2036.

According to the report, there is currently no reliable, accurate, and reproducible technical method for directly measuring recycled metal content in a finished product. As a result, verification is expected to rely on traceability systems and documentation.

Under the proposed approach, battery manufacturers would collect evidence from preceding supply-chain actors using at least a "one step up, one step down" data-sharing model. In this system, each company maintains its own traceability records and shares defined information with its immediate suppliers and customers.

The report does not select a single preferred traceability model. Instead, it assesses different options and the trade-offs they entail for business continuity, competitiveness, resource efficiency, climate impact, consumer confidence, administrative burden, and ease of verification by notified bodies.

Plant-level mass balance in focus

A central option in the report is plant-level mass balance with volume reconciliation. Under this approach, companies would reconcile recycled inputs and outputs over a defined accounting period rather than proving the recycled content of each individual batch.

The JRC said this flexibility is needed because battery-material supply chains often involve continuous and batch processes, the mixing of primary and recycled materials, multiple production sites and complex material flows, particularly for metals such as nickel and cobalt.

Recycled content would be calculated as the mass of recycled metal divided by the total mass of that metal in the relevant battery component, then multiplied by 100.

For cobalt, lithium, and nickel, the calculation applies to the share present in active materials and recovered from battery manufacturing waste or post-consumer waste. For lead, it applies to the share present in the battery and recovered from waste.

The calculation must be performed for each battery model, each year, and each manufacturing plant, in accordance with Article 8.

The JRC assessed three broad traceability approaches: mass balance with a rolling average for battery manufacturers, with upstream actors using segregation or controlled blending; mass balance with a rolling average for all supply-chain actors; and plant-level mass balance with volume reconciliation and credit allocation.

The report found that no option was clearly superior. However, it said that approaches using mass balance with credit allocation performed better at preserving business continuity, supporting competitiveness, and delivering environmental benefits, such as greater resource efficiency and lower emissions.

Platts, part of S&P Global Energy, assessed cobalt payables at 82% ex-works Europe on July 13, stable day over day and week over week, based on European cobalt metal. Nickel payables were also 82%, unchanged day over day and week over week, referencing London Metal Exchange nickel. Platts assessed lithium payables at zero on July 13, unchanged since its April 2023 launch.

The calculated Platts Ni-Co black mass price was $3,910/mt ex-works Europe on July 13, down $1 day over day and up $24 week over week. The black mass assessment reflects the prices for material with a minimum of 3% lithium, 5% cobalt and 12% nickel, and a combined impurity level of less than 5% for copper, aluminum, and iron.