# Is Recycled Content Required on a Battery Passport in 2027?

Source: https://activatedigital.ai/knowledge/digital-product-passport/batteries/recycled-content
Last verified: 7 November 2026
Summary: **Short answer:** No. The recycled content shares for cobalt, lithium, nickel and lead sit in the public part of the battery passport under Annex XIII point 1(e) of Regulation (EU) 2023/1542, but they only have to be documented from the later of 18 August 2028 and 24 months after a Commission delegated act that is still a draft. The Commission's own guidance marks the four rows "Not to be filled/displayed as of February 2027". Unlike the carbon footprint, these shares cannot be estimated at all: the draft act defines each one as a documented mass balance at the maker's plant. What chemistry can tell you is which metals are not in the battery in the first place.

- Documentation is due the later of **18 August 2028** and 24 months after the Article 8 delegated act enters into force.
- The draft act of 12 August 2026 defines the share as a plant level mass balance based exclusively on documentation. It is not adopted.
- LFP batteries have no cobalt or nickel in their active material, so those rows say so.

## What the Regulation asks for

Article 8(1) says that from "18 August 2028 or 24 months after the date of entry into force of the delegated act ..., whichever is the latest", covered batteries "shall be accompanied by documentation containing information about the percentage share of cobalt, lithium or nickel that is present in active materials and that has been recovered from battery manufacturing waste or post-consumer waste, and the percentage share of lead that is present in the battery and that has been recovered from waste, for each battery model per year and per manufacturing plant" ([Regulation (EU) 2023/1542, Article 8](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng)).

It applies to industrial batteries over 2 kWh with internal storage, electric vehicle batteries and SLI batteries that "contain cobalt, lead, lithium or nickel in active materials". Light means of transport batteries join on 18 August 2033. The passport row, Annex XIII point 1(e), is "recycled content information as contained in the documentation referred to in Article 8(1)". SLI batteries have no passport but must give the same information through their QR code under Article 13(6)(c).

Minimum shares follow later: from 18 August 2031, 16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel; from 18 August 2036, 26 % cobalt, 85 % lead, 12 % lithium and 15 % nickel.

Two definitions matter. "Battery manufacturing waste" means material "rejected during the battery manufacturing process, which cannot be re-used as an integral part in the same process and need to be recycled" (Article 3(1)(51)), so pre-consumer scrap that leaves the process counts, run-around scrap that goes straight back in does not. And the share is of the element in the active materials (for cobalt, lithium and nickel) or in the whole battery (for lead), not of the battery's mass.

## Where the delegated act stands

The Commission was to adopt the act "by 18 August 2026". A draft was published for feedback on 12 August 2026 and feedback closed on 9 September 2026 with 70 responses; it is in inter-service consultation and not adopted ([Have your say 14858](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14858-Methodology-for-calculation-and-verification-of-recycled-content-in-batteries_en)). Because the obligation runs 24 months after the act takes effect, every month of delay now moves the documentation date past 18 August 2028.

The draft sets the method as "plant-level mass balance with volume reconciliation and credit allocation", with a traceability system "based exclusively on documentation" and a temporary "correction factor of 1,3" for lithium, nickel and cobalt recovered through recycling in the EU, "not for lead" ([draft delegated act and annex, August 2026](https://ec.europa.eu/info/law/better-regulation/api/download/090166e531e722e9)). It is built on a JRC study of July 2026 which, as reported, found no reliable and reproducible technical method for measuring recycled metal content directly, so compliance rests on chain of custody records ([S&P Global on the JRC recycled content study](https://www.spglobal.com/energy/en/news-research/latest-news/metals/071426-eu-study-sets-out-battery-recycling-tracking-rules)).

Data points 20 to 23 of the Commission guidance carry the words "Not to be filled/displayed as of February 2027- to be applied as envisaged by Article 8" ([Commission guidance, data points by category](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital%20Batteries%20Passport%20-%20data%20point%20by%20category.pdf)).

## Why this field cannot be estimated

A carbon footprint is a physical quantity that a model can approximate from public averages, with a range. A recycled content share is a documented quantity: the recycled mass of the element that entered this plant's production of this model in this year, divided by the total mass of that element. No public dataset describes that. What the public datasets describe is the market:

| Metal | Market context (not a battery's value) | Source |
|---|---|---|
| Cobalt | "recycled (e.g. secondary) cobalt currently represents around 5% of global supply" | [Cobalt Institute, January 2025](https://www.cobaltinstitute.org/wp-content/uploads/2025/01/Responsible_Secondary_Cobalt.pdf) |
| Lithium | "The median contribution of lithium recycling to total battery production is expected to be 0.7%" in 2025 | [Kresse et al. 2025, Recycling](https://www.mdpi.com/2313-4321/10/4/122) |
| Nickel | Recycled nickel met 31 % of all nickel demand in 2023, mostly stainless steel scrap rather than battery grade | [IEA, Recycling of Critical Minerals](https://www.iea.org/reports/recycling-of-critical-minerals/executive-summary) |
| Lead | "The average lead battery made in the EU today contains more than 80% recycled materials" | [EUROBAT](https://www.eurobat.org/wp-content/uploads/2022/03/Circular_Economy_v3.pdf) |

Putting any of those numbers in the passport row would misstate a legal quantity. We show them, if at all, in a separately labelled context note.

## What chemistry does tell you

The field only applies to metals "present in active materials". A lithium iron phosphate battery has no cobalt and no nickel in its cathode, so for those two rows the honest entry is "not present in active material", which is a fact about the chemistry, not an estimate. Lithium is present, so that row is "not declared by manufacturer" until the maker documents it. Lead applies to lead acid batteries and to nothing else in practice.

| Chemistry on the passport | Cobalt | Lithium | Nickel | Lead |
|---|---|---|---|---|
| LFP (lithium iron phosphate) | Not present in active material | Applies, not declared | Not present in active material | Not present |
| NMC, NCA (nickel based) | Applies, not declared | Applies, not declared | Applies, not declared | Not present |
| Lead acid | Not present | Not present | Not present | Applies, not declared |
| Sodium ion | Depends on the cathode; usually not present | Not present | Depends on the cathode | Not present |

Capacity and chemistry also let a passport estimate how much of each metal the battery contains, which is the denominator of the share. That is useful for the maker's own calculation. It never supplies the numerator.

## What the passport should show today

The row reads "Not yet required (Article 8(1); draft delegated act of 12 August 2026, not adopted). Not declared by manufacturer." Where the chemistry rules a metal out, that row reads "Not present in active material". For light means of transport batteries, the row adds that the obligation applies from 18 August 2033. There is no estimate block for this field.

## What a maker has to send to declare a share

Per model, per year, per plant: the recycled and total mass of cobalt, lithium and nickel in the active materials and of lead in the battery, split into pre-consumer and post-consumer waste, with the chain of custody documents or third party certificate behind the mass balance. Once the act is adopted, the documentation in the format it sets. A supplier letter saying cells "contain recycled material" with no masses is not a declaration and leaves the row as not declared.

Our [71 data points guide](https://activatedigital.ai/knowledge/digital-product-passport/batteries/71-data-points) places these rows in the Commission's numbering. [Where battery passport data comes from](https://activatedigital.ai/knowledge/digital-product-passport/batteries/data-origins) covers the evidence objects a maker already holds.

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## What would change this page

- Adoption and publication of the delegated act under Article 8(1), which starts the 24 month clock and fixes the documentation format.
- A change to the Article 8 dates or targets through the review the Commission must complete by 31 December 2028.
- A manufacturer documenting recycled content shares for a battery model we hold a passport for.

## Frequently asked questions

### Do the recycled content rows have to be filled on 18 February 2027?

No. The Commission guidance marks data points 20 to 23 as not to be filled or displayed as of February 2027. The obligation under Article 8(1) starts on the later of 18 August 2028 and 24 months after the delegated act enters into force.

### Can we use an industry average for recycled cobalt?

No. The share is defined per model, per year and per plant from documented mass balance. A market average describes the market, not the battery. It should appear only as a labelled context note if at all.

### Does an LFP battery need recycled cobalt and nickel shares?

No. Article 8 applies to metals present in active materials. LFP cathodes contain neither. Those rows can say so. The lithium row still applies.

### What counts as recycled content under the Regulation?

Cobalt, lithium or nickel in the active materials recovered from battery manufacturing waste or post-consumer waste, plus lead in the battery recovered from waste. Internal scrap that goes straight back into the same process does not count.

### Is there a test that measures recycled content?

No. The JRC study behind the draft act found no reliable physical method, which is why the draft relies on documentation and mass balance.

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## Get a free passport check

Bring one battery model and its chemistry. We'll show which recycled content rows apply to it, what each should say today and what to ask the maker for. [Request a free passport check](https://activatedigital.ai/about#contact).

## Keep exploring

The questions this page usually raises next.

- [CompareNext questionWhat Goes in a Battery Passport When the Manufacturer Hasn't Published the Data?Carbon footprint, recycled content, renewable content and who declared what are blank on every real battery passport.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/fields-no-maker-publishes-yet)
- [CompareNext questionWhat Is Renewable Content in a Battery Passport and What Do You Show?Renewable content is due on the battery passport from 18 February 2027 with no definition behind it.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/renewable-content)
- [CompareNext questionCan You Estimate a Battery's Carbon Footprint for the EU Battery Passport?The passport carbon footprint is per kWh of lifetime energy, not capacity. No maker has declared one.→](https://activatedigital.ai/knowledge/digital-product-passport/batteries/carbon-footprint)

## Primary sources

- [Regulation (EU) 2023/1542, Article 8](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng) EU law
- [Have your say 14858](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14858-Methodology-for-calculation-and-verification-of-recycled-content-in-batteries_en)
- [draft delegated act and annex, August 2026](https://ec.europa.eu/info/law/better-regulation/api/download/090166e531e722e9)
- [S&P Global on the JRC recycled content study](https://www.spglobal.com/energy/en/news-research/latest-news/metals/071426-eu-study-sets-out-battery-recycling-tracking-rules)
- [Commission guidance, data points by category](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital%20Batteries%20Passport%20-%20data%20point%20by%20category.pdf)
- [Cobalt Institute, January 2025](https://www.cobaltinstitute.org/wp-content/uploads/2025/01/Responsible_Secondary_Cobalt.pdf)
- [Kresse et al. 2025, Recycling](https://www.mdpi.com/2313-4321/10/4/122)
- [IEA, Recycling of Critical Minerals](https://www.iea.org/reports/recycling-of-critical-minerals/executive-summary)
- [EUROBAT](https://www.eurobat.org/wp-content/uploads/2022/03/Circular_Economy_v3.pdf)