Recycled Content Targets: What Cell Makers Must Hit and When

Regulation (EU) 2023/1542 requires certain batteries, including EV batteries and industrial batteries with internal storage, to document the share of cobalt, lead, lithium and nickel recovered from waste present in their active materials. Documentation obligations come first, with the calculation and verification methodology set by a delegated act.

Binding minimum shares then follow in two steps. The regulation sets initial minimum levels from 2031 and higher levels from 2036, and gives the Commission powers to review them in light of market conditions. Cell makers and battery producers selling into the EU need to plan supply contracts now, because recycled material capacity takes years to build.

India's Battery Waste Management Rules 2022 also address recycled material use, setting obligations on producers to use a minimum share of domestically recycled materials in new batteries, phased in over several years and differentiated by battery category. The aim is to build domestic recycling capacity alongside the growth in battery demand.

For producers, that means recycled content is not only an export consideration but a domestic compliance matter. Securing supply from registered Indian recyclers and keeping records of material origin will be necessary to demonstrate compliance as the obligations take effect.

Meeting recycled content requirements depends on proving where material came from. Chain-of-custody records must link recovered metal salts back to specific waste inputs, and the method for attributing recycled content, whether mass balance or physical segregation, must follow the approved methodology.

Cell makers typically secure recycled material through long-term offtake agreements with refiners, sometimes combined with take-back of their own production scrap and end-of-life packs. Qualification of recycled material for cell production takes time, so early engagement between recyclers, precursor producers and cell makers is essential.