Recycled Content Thresholds.

The EU Battery Regulation sets minimum recycled content thresholds for four materials used in batteries: cobalt, lithium, nickel, and lead. These thresholds phase in over two stages — 2031 and 2036.

The thresholds

What the percentages mean

The percentage represents the proportion of the material's total weight in the battery that comes from recycled sources. For example, if your EV battery contains 10 kg of cobalt and 1.6 kg of that cobalt was recovered from recycled batteries, your recycled cobalt content is 16%.

"Recycled sources" means material recovered from post-consumer waste or manufacturing scrap through recycling processes. Virgin material extracted from mines does not count.

How to calculate recycled content

The calculation for each material is:

Recycled content (%) = (mass of recycled material in battery / total mass of that material in battery) × 100

The mass values must be supported by documentation from your supply chain. This typically means:

1. Bill of materials — listing the total mass of each material in the battery.
2. Supplier certificates — confirming the mass and origin of recycled material supplied.
3. Chain of custody documentation — tracing recycled material from the recycler through to your battery production.

What to enter in EU Digital Passport Processor

The Sustainability section of the passport wizard includes four recycled content fields — one for each material. Enter the percentage as a number (e.g., 16, not 16%). If your battery does not contain a particular material (e.g., an LFP battery contains no cobalt or nickel), enter 0 or leave the field blank with a note.

Before 2031

Until the 2031 thresholds take effect, recycled content fields are optional in EU Digital Passport Processor. You can declare your current recycled content percentages voluntarily. Doing so improves your compliance strength score and demonstrates supply chain preparedness to customs authorities and customers.