Guide · Compliance & EPR

Reporting Recycled Content in Sustainability Disclosures

Recycled content claims need chain-of-custody evidence linking recovered mass to specific input batches.

Priya Nair

EPR & Compliance Lead

3 min read Updated 2026-04-22

Compliance team reviewing chain-of-custody documents on a large screen in a modern meeting room, screen content abstract

The short answer

Recycled content claims need chain-of-custody evidence linking recovered mass to specific input batches. Mass-balance allocation must be disclosed as such rather than presented as physical content.

On this page4 sections

Key takeaways

1Recycled content claims need a documented chain of custody from input material to output product.
2The chosen accounting method, such as mass balance or physical segregation, must be disclosed.
3EU rules will require documented recycled content for certain batteries in future phases.
4Inconsistent definitions are the most common source of misleading claims.

What counts as recycled content

Recycled content usually means material recovered from waste and returned to production. For batteries, the key question is whether the source is post-consumer waste, such as end-of-life EV packs, or pre-consumer waste, such as manufacturing scrap. The EU Battery Regulation counts both in its recycled content provisions but requires the share from each to be documented.

Definitions matter because they change the headline figure. A company that includes production scrap will report a higher number than one that counts only end-of-life material. Neither is wrong, but the basis must be stated so readers can compare like with like.

Accounting methods

Physical segregation keeps recycled material separate through the supply chain, which gives the most direct claim but is hard to maintain at scale. Mass balance allows recycled and virgin material to mix, with the recycled share allocated to outputs based on documented inputs. Mass balance is widely used, but it depends on robust records and clear allocation rules.

Whichever method is used, the disclosure should name it, describe the boundaries and explain how double counting is avoided. Buyers of recycled material increasingly ask for certificates that link a specific quantity of recycled content to their purchase.

Approach	How it works	Main consideration
Physical segregation	Recycled material kept separate end to end	Operationally demanding
Controlled blending	Mixed at known, measured ratios	Ratio must be verifiable
Mass balance	Recycled share allocated by documented inputs	Needs strict records to avoid double counting

Chain-of-custody approaches

Preparing for regulatory scrutiny

The EU Battery Regulation requires documentation of recycled cobalt, lithium, nickel and lead content for certain batteries, with minimum shares applying in later phases. Detailed calculation and verification rules are set through secondary legislation, so companies should follow those developments closely rather than rely on early assumptions.

Practical preparation starts with supplier data. Ask refiners and precursor producers for recycled content certificates, verify them where possible, and keep records in a form an auditor can follow. Claims made in sustainability reports should use the same basis as claims made to regulators.

State whether pre-consumer scrap is included
Name the chain-of-custody method used
Keep supplier certificates linked to purchase records
Use one consistent basis across reports and regulatory filings

Questions

Frequently asked questions

Does production scrap count as recycled content?

Under the EU Battery Regulation it can, but the shares from manufacturing waste and post-consumer waste must be documented separately.

Is mass balance accepted for recycled content claims?

It is widely used, but acceptance depends on the specific scheme or regulation and on robust records that prevent double counting.

Turn this into a plan for your packs

Send pack counts, chemistry and approximate state of health. You get an indicative value split, a slotted collection window and pre-filled dangerous goods paperwork.

Run the yield calculator

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