Delegated Regulation on Recycled Content Methodology for Batteries

Energy Storage Europe replies to the European Commission’s public consultation on the Methodology for the Calculation of the recycled content of industrial and EV batteries. Under the Batteries Regulation, several categories of batteries, including industrial batteries, will have to contain a certain percentage of recycled metals to be allowed to be placed on the EU market. In particular, the Regulation sets recycled content targets for lithium, cobalt, nickel and lead. Two sets of targets will apply from 2031 and 2036, respectively.

Energy Storage Europe welcomes the draft Delegated Regulation and supports its overall direction, noting that it provides workable methodological flexibility while preserving traceability integrity. Energy Storage Europe particularly supports broadening the credit-allocation route beyond toll-treatment alone to cover eligible contractual agreements more generally. Energy Storage Europe also supports the temporary correction factor of 1.3 for lithium, nickel and cobalt recycled within the Union until 31 December 2036, which rightly rewards EU circularity.

However, Energy Storage Europe calls on the Commission to address several points to ensure the methodology works in practice: clarifying how the correction factor applies to actors with mixed EU/third-country recycling chains, addressing the abrupt drop in documented recycled content that the 2036 cliff-edge would create, keeping the new origin-tracking requirements proportionate and aligned with existing traceability records, and confirming whether limited carryover of positive credits between accounting periods could better accommodate legitimate production and supply-chain fluctuations.