Executive Summary

The rules for the calculation and verification of recycled content in batteries can play in important role in stimulating demand for recycled materials sourced within the EU, and strengthening the EU market for recycled materials, while enabling brands to make credible recycled content claims. In this context, Recycling Europe welcomes the draft Delegated Act’s use of efficient and proportionate provisions, and highlights that its implementation should be monitored regularly to assess its effectiveness. However, several elements require clarification and improvement as they could risk turning recycling from a material-based business model towards a service model, thus having devastating consequences for the recycling industry. The final rules should ensure that they support investment in European recycling capacity, preserve the value of recycled materials and effectively contribute to a competitive and circular battery value chain.