Recycled Content and recovery targets

Article 8 is a product compliance requirement, not a recycler performance target. It applies to industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle batteries, and SLI batteries where the battery contains cobalt, lead, lithium, or nickel in active materials. LMT batteries join the Article 8 documentation requirement later under the same material trigger.

The documentation is prepared for each battery model, per year, and per manufacturing plant. For cobalt, lithium, and nickel, the share is the percentage present in active materials that was recovered from battery manufacturing waste or post-consumer waste. For lead, the share is the percentage present in the battery that was recovered from waste.

Article 8 does not cover copper as a recycled-content material. Copper appears in Annex XII material recovery targets for waste-battery recycling, so keep copper out of Article 8 product recycled-content declarations unless a later delegated act adds it.

The first Article 8 step is documentation. For industrial batteries greater than 2 kWh except those with exclusively external storage, electric vehicle batteries, and SLI batteries, the documentation duty starts on 18 August 2028 or 24 months after the Article 8 methodology delegated act enters into force, whichever is later. For LMT batteries, the documentation duty starts on 18 August 2033.

The first minimum recycled-content shares apply from 18 August 2031 to industrial batteries greater than 2 kWh except those with exclusively external storage, electric vehicle batteries, and SLI batteries: 16% cobalt, 85% lead, 6% lithium, and 6% nickel. The later minimum shares apply from 18 August 2036 to those categories and LMT batteries: 26% cobalt, 85% lead, 12% lithium, and 15% nickel.

Do not treat those minimum shares as already applicable to every battery. The trigger depends on battery category, capacity, storage configuration, material content, model-year-plant boundary, and the Article 8 application date.

Annex XII Part B is about recycling efficiency for waste batteries. It is measured by battery chemistry, not by the Article 8 recycled-content model-and-plant record. The 2025 targets are 75% by average weight for lead-acid batteries, 65% for lithium-based batteries, 80% for nickel-cadmium batteries, and 50% for other waste batteries.

The 2030 Annex XII recycling efficiency increases are narrower: 80% by average weight for lead-acid batteries and 70% for lithium-based batteries. Annex XII does not list a 2030 increase for nickel-cadmium or other waste batteries in the same Part B target table.

Use the Annex XII chemistry names when tracking recycling efficiency. Do not recast them as product categories such as EV, LMT, SLI, or industrial batteries unless the underlying waste stream and reporting source support that mapping.

Annex XII Part C sets recovery-of-materials targets for five materials from waste-battery recycling: cobalt, copper, lead, lithium, and nickel. This is where copper belongs in the Batteries Regulation target set; it is not part of the Article 8 recycled-content list unless added later through delegated powers.

By 31 December 2027, recycling must achieve at least 90% recovery for cobalt, copper, lead, and nickel, and 50% for lithium. By 31 December 2031, the targets rise to 95% for cobalt, copper, lead, and nickel, and 80% for lithium.

A useful recovery record should preserve the target material, input fraction, output fraction at the material-recovery calculation point, Member State collection context where relevant, and the calendar year covered by the calculation.

Delegated Regulation (EU) 2025/606 does not set the Article 8 recycled-content methodology. It supplements the Batteries Regulation under Article 71 by establishing the methodology for calculating and verifying recycling efficiency and recovery of materials from waste batteries, plus the format for recycler documentation.

The methodology applies separately to lead-acid, lithium-based, nickel-cadmium, and other waste batteries for recycling efficiency. For material recovery, it covers cobalt, copper, lead, lithium, and nickel. The documentation format requires recycler identity, calendar year, battery chemistry, treatment flow, input, intermediate and output fractions, calculated rates, and information about cadmium and mercury streams where relevant.

Where recycling occurs in more than one permitted facility, the first recycler is responsible for collecting and providing the information to competent authorities. The documentation must cover all individual recycling steps and corresponding output fractions, so an isolated facility spreadsheet is not enough when the process spans multiple operators.

Keep three records distinct. First, the Article 8 product recycled-content file proves the recycled share for a battery model, year, and manufacturing plant. Second, the Annex XII recycling-efficiency file proves chemistry-specific recycler performance for waste batteries. Third, the Annex XII material-recovery file proves recovery rates for cobalt, copper, lead, lithium, and nickel at the correct calculation point.

Annex VIII connects Article 8 to conformity evidence: the technical documentation must include a study supporting the recycled-content share, the calculations made under the Article 8 methodology, and the evidence and information determining the input data. It also requires quality-system procedures for documenting and monitoring the parameters and data needed to calculate and update recycled-content shares.

For public claims, avoid broad statements such as 'contains recycled critical minerals' unless the record identifies the battery category, material, percentage, model, manufacturing plant, year, and source of recovered waste. For recycler claims, identify the chemistry or target material and the Delegated Regulation 2025/606 documentation behind the number.