he European Commission has formally adopted a delegated regulation on 21 March 2025 establishing a standard methodology for calculating recycling efficiency and material recovery from waste batteries across the EU. Applicable under Regulation (EU) 2023/1542, this measure directly affects manufacturers, recyclers, and suppliers handling lead-acid, lithium-based, nickel-cadmium, and other batteries, introducing strict documentation and performance requirements to ensure sustainability, compliance, and market consistency.
Harmonised Battery Recycling Metrics Now Law
The new delegated regulation, C(2025)1674, introduces a compulsory formulaic approach for calculating the recycling efficiency (rRE) and material recovery rates (rRM) for critical materials such as lithium, cobalt, nickel, copper, and lead. These metrics must be measured at specified calculation points within the recycling process, ensuring that only usable output materials—those substituting primary raw materials—are counted.
The policy mandates recyclers to account for input, intermediate, and output fractions across every step of the recycling chain and submit detailed documentation by Member State annually. Verification will be enforced by competent national authorities, with audits and site visits included as standard procedure.
Impact on Battery Manufacturers and Recyclers
Battery producers must ensure recyclability through design, while recyclers are now held to transparent and verifiable recovery rates. From 2026, annual reporting using uniform documentation templates becomes mandatory. Notably, mercury and cadmium disposal must be specifically tracked and reported.
The rules also anticipate technological developments: until 2029, recyclers may include carbon, phosphorus, and sulphur in calculations; from 2030, updated compositions will apply.
What This Means for the Industry
Manufacturers will need to partner with compliant recyclers and potentially redesign batteries to meet recovery targets. For logistics providers and recyclers, new opportunities lie in offering traceable, high-yield recovery services. Failure to meet documentation or verification requirements may result in penalties or market access restrictions.
