EU Batteries Regulation Article 8 recycled content calculation FAQ

Article 8 first applies to industrial batteries, electric vehicle batteries, and starting, lighting and ignition batteries that contain cobalt, lead, lithium, or nickel in active materials. For those batteries, documentation of recovered-content shares applies from 18 August 2031.

LMT batteries are phased in separately. The information-documentation requirement applies to LMT batteries containing the same listed materials from 18 August 2033, and LMT batteries are included in the 2036 minimum-share threshold requirement.

The Article 8 material list is narrow: cobalt, lead, lithium, and nickel. For cobalt, lithium, and nickel, the documented share concerns material present in active materials and recovered from battery manufacturing waste or post-consumer waste. For lead, the documented share concerns lead present in the battery and recovered from waste.

Do not add copper, graphite, manganese, steel, aluminium, plastics, or broad recycled-content totals to this FAQ unless a later delegated act or amendment in the source material supports that addition. Article 8 allows the Commission to add other materials by delegated act where justified by battery-chemistry market developments, but the current grounded rule names only cobalt, lead, lithium, and nickel.

From 18 August 2031, technical documentation for the first-wave battery categories must demonstrate minimum recovered-content shares of 16% cobalt, 85% lead, 6% lithium, and 6% nickel, where the battery contains the relevant material in active materials.

From 18 August 2036, the thresholds rise to 26% cobalt, 85% lead, 12% lithium, and 15% nickel, and the covered categories include industrial batteries above 2 kWh except those with exclusively external storage, electric vehicle batteries, LMT batteries, and SLI batteries. Article 8 also requires the Commission to assess whether the targets should be revised after the delegated methodology enters into force and no later than 31 December 2028.

Article 8 documentation is organized by battery model, year, and manufacturing plant. Annex VIII then makes that documentation auditable: technical documentation must include a study supporting the recycled content share, the calculations made under the Article 8 delegated methodology, and the evidence and information determining the input data for those calculations.

For manufacturers using the quality-assurance production-process module, the quality system should also document how the parameters and data needed to calculate and update the Article 8 recycled content share are monitored. The notified body audit checks the reliability of the recycled-content data and whether the calculation methodology has been properly implemented.

No. Article 8 instructs the Commission to adopt a delegated act by 18 August 2026 establishing the calculation and verification methodology for recycled-content percentage shares and the documentation format. The grounding reviewed for this FAQ did not include an adopted Article 8 recycled-content methodology.

Commission Delegated Regulation (EU) 2025/606 is related but different. It establishes methodology and documentation for recycler recycling-efficiency rates and recovery-of-materials rates from waste batteries, including cobalt, copper, lead, lithium, and nickel. Those recycler records can be relevant upstream evidence, but they should not be cited as the Article 8 battery-model recycled-content methodology.