Last month, as an important step in the implementation of the EU Batteries Regulation, the European Commission published a draft Delegated Regulation establishing a common methodology for calculating and verifying recycled content in certain batteries. The proposal covers industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle (EV) batteries, starting, lighting and ignition (SLI) batteries, and light means of transport (LMT) batteries. Stakeholders were invited to contribute to an open consultation.
The Commission has pointed to import reliance of around 81% for cobalt, 75% for nickel and 100% for lithium, while geopolitical tensions and export restrictions are creating additional uncertainty around their supply. In light of this, battery recycling is seen as an important opportunity to increase the availability of secondary raw materials in Europe, reduce dependence on imports and strengthen the resilience of the EU battery value chain.
Under the Batteries Regulation, manufacturers will be required to declare and, at a later stage, meet minimum recycled-content requirements for lithium, cobalt, nickel and lead in several categories of batteries placed on the EU market. The draft Delegated Regulation takes an important step towards putting these requirements into practice. It sets out how recycled content is to be calculated and verified, covering the share of cobalt, lithium and nickel in active materials that has been recovered from battery manufacturing waste or post-consumer waste, as well as the share of lead present in the battery that has been recovered from waste. It also establishes a common format for documenting the data needed to demonstrate and verify these recycled-content levels. At the heart of the proposal is a strong emphasis on traceability across the battery value chain, ensuring that recycled content can be tracked from the moment waste enters a recycling plant to the moment the derived secondary material is used in a battery model.
The development is particularly relevant to FREE4LIB, whose work demonstrates what a more circular European lithium-ion battery ecosystem can look like in practice. The project has developed technologies spanning battery dismantling and pre-treatment, material recovery, reuse and the production of new battery components from recovered materials. FREE4LIB also addresses traceability through its Battery Passport methodology and digital platforms, connecting technological recycling solutions with the information needed across the battery life cycle.
FREE4LIB's combination of advanced recycling technologies, remanufacturing, material re-use and digital traceability is highly relevant to several of the practical challenges highlighted by the emerging regulatory framework.
