Methodology for calculation and verification of recycled content in batteries

70 submissions in the snapshot (65 from organisations), portal total 70. Feedback list on the portal.

65 of 65 organisation submissions analysed; the model reads them as: supports 11 wants changes 43 11 held back for review (low confidence).

• EIT Innoenergy Central Europe Business association, BEL model reads as: wants changes source
  • Add the missing plus sign in formulas 1a' and 1b'.

    In the parentheses, the recycled outputs from third countries and EU countries (multiplied with 1.3) are summed up, but the plus sign is missing.

• LIBREC AG Company, CHE model reads as: wants changes source
  • Extend eligibility for the 1.3 correction factor to recycling facilities operating in the UK, Switzerland, and Norway.

    We ask the Commission to consider extending eligibility for the correction factor to installations in UK, Switzerland, and Norway maintaining equivalent regulatory standards and integrated into the Union's waste framework through international agreements (Basel Convention, bilateral agreements).

• Inci Holding A.Ş. Company, TUR model reads as: wants changes source
  • Clarify the justification for excluding lead from the 1.3 correction factor incentive mechanism.

    We therefore recommend clarifying the justification for excluding lead from this mechanism and indicating whether a similar incentive could be considered for lead in the future.

  • Consider applying a targeted exemption or derogation for advanced products such as AGM and TPPL batteries requiring high-purity lead.

    Where recycled-content requirements could adversely affect product performance, safety, or service life, it may be beneficial to consider a targeted exemption or derogation mechanism for such product categories based on demonstrated technical necessity.

  • Provide clearer guidance on third-country facility audits to guarantee equal treatment for non-EU manufacturers.

    We recommend providing greater clarity on the practical implementation of audits at third-country facilities and confirming that the requirements will be applied in a manner that ensures equal treatment between EU and non-EU manufacturers.

• TOYOTA BATTERY Co., Ltd. Company, JPN model reads as: wants changes source
  • Exclude obsolete battery models supplied only as service or replacement parts from the regulation scope.

    Batteries that have become obsolete models and are supplied only as service / replacement parts should be excluded from the scope.

  • Include direct recycling within the scope of the regulation.

    In addition, as noted in other submissions, we also support the view that direct recycling should be covered under the scope.

• Deutsche Umwelthilfe NGO, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Restrict chain of custody methodologies strictly to segregation and controlled blending rather than mass balance with volume reconciliation and credit allocation.

    We therefore propose to only allow the methods segregation and, in case needed, controlled blending as proposed by the JRC in option 1a for all supply chain actors in the JRC draft recommendations in November 2024.

  • Maintain the full ambition of recycling target requirements without reductions.

    Although we support efforts to promote the use of materials derived from European waste, we are firmly opposed to any reduction in recycling target requirements in this context.

• Inci Aku Sanayi ve Ticaret Anonim Sirketi Company, TUR model reads as: wants changes source
  • Clarify the rationale for excluding lead from the 1.3 correction factor incentive.

    The rationale for this exception for lead needs to be clarified, and it should be stated whether a similar incentive will be considered in the future.

  • Consider an exemption or derogation mechanism for high-performance battery categories where recycled-content rules could impair product performance or safety.

    If potential recycled content requirements risk negatively impacting product performance, safety, and lifespan, it is considered beneficial to evaluate an exemption or derogation mechanism based on technical grounds for the relevant product categories.

  • Clearly define and ensure equal application of audit processes at third-country facilities.

    It is essential that the audit processes at third-country facilities be clearly defined and applied on equal terms with EU manufacturers.

• Robert Bosch GmbH Company, DEU; register: Companies & groups model reads as: wants changes source
  • Adjust provisions regarding operational boundaries, credit allocation flexibility, and the ban on credit carryover.

    However, to ensure international competitiveness, investment security, and administrative feasibility for global industries, key adjustments to the proposal are required regarding the operational boundaries (site-level restriction), commercial flexibility in credit allocation, and the prohibition of credit carryover.

• UL Solutions Company, USA; register: Companies & groups model reads as: wants changes source
  • Clarify several key areas to improve legal certainty, ensure practical implementation, and avoid inconsistent interpretation.

    Based on a detailed technical review conducted by our experts, we believe that further clarification is needed in several areas to enhance legal certainty, prevent inconsistent interpretation, and ensure practical implementation throughout complex global battery supply chains.

• EGMF Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Clarify documentation rules for battery models produced and CE marked in the reporting year to avoid administrative uncertainties.

    We therefore kindly urge the Commission to clarify this point to ensure manufacturers are not faced with reporting and administrative uncertainties.

• Mili - Recycling for Israel Ltd Company, ISR model reads as: wants changes source
  • Amend Section 2.2.5 to apply the correction factor where pre-treatment takes place in a third-country facility, provided refining occurs in the Union and traceability is maintained.

    Our request one targeted amendment to Section 2.2.5: the factor should also apply where pre-treatment took place in a third-country facility, provided that refining is carried out in the Union, the material returns to the Union battery chain, and full traceability is maintained.

  • Include a periodic public review and withdraw the temporary factor once the shortage passes.

    A factor defined as "temporary" should also include a periodic public review and its withdrawal once the shortage has passed.

• GS Yuasa International Ltd. Company, JPN model reads as: wants changes source
  • Relax recycling rate requirements for countries and regions where lead-acid battery collection schemes are well established.

    For countries and regions, such as Japan, where collection schemes for lead-acid batteries are well established, the recycling rate requirements should be relaxed.

• Saft Company, FRA model reads as: wants changes source
  • Provide flexibility in the nickel and cobalt chain of custody for existing battery technologies reliant on mature recycling processes.

    Therefore, it is necessary to allow some flexibility in the Ni and Co chain of custody for existing battery technologies, relying on mature recycling processes, produced by actors who provide jobs and industrial activity (manufacturing and recycling) in Europe.

• Koluman Otomotiv Endüstri A.Ş. Company, TUR model reads as: wants changes source
  • Downstream vehicle manufacturers should be permitted to rely on verified supplier documentation rather than duplicating upstream calculations or records.

    Vehicle manufacturers should be allowed to rely on verified supplier documentation without duplicating upstream calculations, mass-balance records or commercially sensitive data.

  • The regulation should introduce a standardised compliance statement, clear criteria for battery models, and clarity on the allocation of upstream obligations.

    We also recommend a standardised Battery Recycled Content Compliance Statement, clearer criteria for the definition of a battery model, and clarification that upstream accounting periods, rolling-average calculations and record-retention obligations remain with the supply-chain actor responsible for the relevant activity.

  • Clear and proportionate verification rules need to be set for non-EU suppliers.

    Clear and proportionate verification rules should also be established for non-EU suppliers.

• Energy Storage Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should provide guidance clarifying the application of the EU recycling correction factor to partial or mixed recycling chains.

    Guidance on the treatment of partial-EU chains would prevent unintended penalisation of legitimate cross-border operations.

  • The Commission should establish a review or phase-out mechanism to prevent an abrupt drop in documented recycled content after 2036.

    We invite the Commission to consider a phase-out or review mechanism to avoid a discontinuity.

  • The Commission should confirm whether the exclusion of credit carryover is intended and assess allowing limited carryover of positive credits.

    We ask the Commission to confirm this is the intended design and to consider whether limited carryover of positive credits would better accommodate legitimate production and supply-chain fluctuations, without compromising anti-double-counting safeguards.

• Nyrstar Company, NLD model reads as: wants changes source
  • The definition of recycled content should be widened to cover industrial residues and by-products that functionally replace primary raw materials.

    For these reasons, we propose to include any material that functionally replaces primary raw material, like industrial residues or by-products by broadening the definition of "recycled content" materials accordingly.

  • A dedicated accounting mechanism such as credit allocation should be implemented for internally reused industrial residues or by-products.

    Implementing a suitable, separate accounting system, such as credit allocation, to acknowledge the circular value of industrial residues or by-products that are internally reused would give companies a further incentive to prevent waste.

• EURAMET e.V. NGO, DEU; register: Other organisations, public or mixed entities model reads as: wants changes source
  • The methodology needs to define how documentary chain-of-custody and physical measurement methods, sampling, and calibration support each other and are verified.

    Sections 2.3.2, 3.1 and 3.2 should specify how measurement methods, sampling and calibration are documented and verified, proportionate to their significance for the recycled-content result.

  • A consistent, standardised framework for evaluating and reporting measurement uncertainty should be established across the technical documentation and conformity checks.

    Recommendation: Specify a consistent approach to assessing and reporting measurement uncertainty in Section 3.1 and the documentation supporting Tables 3 to 5.

  • European standards and matrix-matched reference materials traceable to the SI should be developed to ensure consistent measurement across testing and recycling facilities.

    We recommend coordinated development of European standards and matrix-matched reference materials with certified values traceable to the SI, where applicable.

• AURUBIS AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Widen the definition of recycled content to include industrial residues and by-products that functionally substitute primary materials.

    We believe that the definition of recycled content should therefore be widened to include any substance that results in the functional substitution of primary materials such as industrial residues/by-products.

  • Apply the correction factor equally to all battery materials covered by the regulation, including lead.

    If such correction factor is needed, it shall apply equally to all battery materials covered by the Batteries Regulation, including lead.

  • Ensure the final calculation methodology maintains a level playing field across different battery chemistries.

    We ask the Commission to ensure that the final methodology preserves a level playing field across battery chemistries.

• Micro company, FRA Academic or research institution, FRA model reads as: wants changes source
  • Reassess and amend the design of the correction factor for EU recycling.

    (1) the proposed correction factor design for EU recycling must be reassessed and amended;

  • Condition eligibility for benefits such as credit allocation to materials recycled in the EU.

    (2) the importance of conditioning eligibility to benefits (such as credit allocation) to EU recycled materials

  • Evaluate and address the risk of market distortion for NCM chemistries between European and Asian cell producers.

    (3) the risk of market distortion posed by the delegated act for NCM chemistries must be evaluated and addressed by the Commission as it may reinforce the gap between European and Asian cell producers.

• Finnish Minerals Group Company, FIN; register: Companies & groups model reads as: wants changes source
  • Permit EU-mined and EU-processed lithium, nickel, and cobalt to count towards Article 8 targets until 31 December 2036.

    Parallel to using recycled metals, battery producers should be permitted to use lithium, nickel and cobalt that has been both mined and processed in the EU as an eligible feedstock counting towards the Article 8 targets.

• EUCOBAT Business association, BEL; register: Trade and business associations model reads as: supports source
• Volvo Cars Company, SWE; register: Companies & groups model reads as: wants changes source
  • Incentivise EU recycled content through differentiated target levels instead of an accounting multiplier.

    We would propose instead to incentivise EU recycled content by setting up differentiated targets as follow: For material recycled outside of EU, the minimum level of RC for material X is 6%; For material recycled inside of EU, the minimum level of RC for material X is 4.6%; For material recycled both inside and outside of EU, the minimum level of RC for material X should be extrapolated between these numbers according to the material share.

• Circular Materials Company, ITA model reads as: wants changes source
  • The Commission should account for the regulatory gap concerning secondary nickel from industrial waste streams outside the battery sector in future policy reviews.

    We nevertheless encourage the Commission to take this regulatory gap into account in the future development and review of the Batteries Regulation and in its interaction with the CRMA, the Circular Economy Act and the EU advanced-materials framework.

  • The Commission should recognize and incentivize secondary nickel recovered from industrial waste streams outside the battery sector when it meets quality and traceability criteria.

    In particular, the Commission should consider how secondary nickel recovered from industrial waste streams outside the battery sector can be appropriately recognised and incentivised where it is demonstrably recovered, traceable, technically suitable and capable of substituting primary nickel in the battery value chain.

  • EU rules should promote cross-sectoral circularity and avoid favoring closed-loop recycling over other valid recovery methods.

    More broadly, EU legislation should support cross-sectoral circularity and avoid regulatory approaches that unnecessarily privilege closed-loop recycling over other technically valid recovery pathways.

• Heyi Green Foundation NGO, CHN model reads as: wants changes source
  • The Commission should delete the 1.3 correction factor and its associated provisions.

    Delete the 1.3 correction factor.

  • Claim accounting rules should be completed by replacing volume with mass reconciliation and establishing a full claims lifecycle.

    Complete claim accounting.

  • An auditable time model should be established to clearly define accounting periods and align reporting obligations.

    Create one auditable time model.

• Micro company, POL Business association, POL model reads as: wants changes source
  • The Commission should recognize industrial by-products and process residues that substitute primary raw materials.

    Recognise industrial by-products and process residues that demonstrably substitute primary raw materials, within the limits of the empowerment in Article 8(1), and feed the resulting data into the assessment the Commission must carry out under Article 8(5) by 31 December 2028.

  • Rules must confirm that internally circulating materials in integrated production systems are not treated as new primary inputs.

    Confirm that materials circulating internally in an integrated production system are not new primary inputs at each process step, and that a metal unit is counted once only.

  • Explicit rules should be established for lead-bearing materials from integrated non-ferrous metallurgy.

    Provide explicit rules for lead-bearing materials from integrated non-ferrous metallurgy, including co-product allocation and confirmation that a smelter or refinery treating waste classified feedstock is a recycler for the purposes of the Annex.

• RECHARGE Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Address risks in the proposed 1.3 correction factor to avoid reducing recycled material availability.

    Correction factor for EU recycling (Section 2.2.5) is overall positive in its intent, but it risks undermining European value chain development if weaknesses are not addressed in the right way.

  • Permit group-level mass balance with volume reconciliation and credit allocation within the same economic area.

    A Group level mass balance with volume reconciliation and free credit allocation within the same economic area under strict requirements brings benefits.

  • Advance the review date of the recycled content targets to the end of 2026.

    RECHARGE recommends advancing the Review of the Recycled Content targets from end 2028 (Article 8 parag. 5) to end 2026.

• Jervois Finland Oy Company, FIN model reads as: wants changes source
  • Define post-consumer waste clearly to include all recycled cobalt regardless of source.

    Post-consumer waste should include all recycled cobalt, regardless of whether it comes from batteries, hard metals, catalysts, superalloys, electronics or other waste streams.

  • Ensure all post-consumer cobalt counts toward Article 8 targets without discriminating by waste stream.

    Post-consumer waste should count towards Article 8 recycled content targets.

  • Avoid restricting battery-recovered cobalt exclusively to new battery applications.

    Restricting battery-derived recycled cobalt exclusively to battery applications would reduce market flexibility, limit the efficient allocation of secondary materials, and create a significant barrier for existing and future recyclers that operate predominantly open-loop recycling models.

• PROSES MAKINA Company, TUR model reads as: wants changes source
  • Make material transparency a mandatory requirement throughout the battery value chain.

    For this reason, we believe that **material transparency should become a fundamental requirement of the battery value chain.**

  • Require battery producers to provide accurate and standardized composition and chemistry data throughout the product lifecycle.

    Battery producers should be required to provide accurate and standardized information about the composition and chemistry of their products throughout their lifecycle.

  • Establish stronger accountability mechanisms when critical material information is missing, incomplete, or inaccurate.

    There should also be stronger accountability mechanisms when critical information is missing, incomplete or inaccurate.

• Royal Netherlands Standardization Institute NGO, NLD model reads as: wants changes source
  • Call for standardisation work through CEN/CENELEC to provide harmonised implementation methods in support of Article 8 of Regulation (EU) 2023/1542.

    we advise the European Commission to consider calling for standardisation work (through CEN/CENELEC) in support of Article 8 of Regulation (EU) 2023/1542.

• International Lead Association Business association, GBR; register: Trade and business associations model reads as: wants changes source
  • Recognise the role of industrial by-products rather than linking recycled content solely to waste.

    Linking battery recycled content solely to waste and failing to recognise the important role industrial by-products play in reducing use of virgin material.

  • Avoid applying a correction factor that excludes lead to prevent structural distortion between competing battery chemistries.

    A correction factor for recycled content that applies only to lithium, nickel and cobalt, and not to other raw materials including lead risks structural distortion of the level playing field between competing chemistries.

• CNRS ICGM Academic or research institution, FRA model reads as: wants changes source
  • Complement the metal-based methodology with specific provisions for directly recycled or regenerated active materials.

    We propose complementing the metal-based methodology with specific provisions for directly recycled or regenerated active materials, without favouring any particular technology.

  • Introduce a complementary indicator measuring the proportion of active material originating from battery waste.

    introducing a complementary indicator measuring the proportion of active material originating from battery waste or battery manufacturing waste;

  • Allow the mass of preserved functional material to be documented alongside the recycled content of lithium, nickel, and cobalt.

    allowing the mass of preserved functional material to be documented alongside the recycled content of lithium, nickel and cobalt;

• Umicore Company, BEL; register: Companies & groups model reads as: wants changes source
  • Prevent the leakage of recycled-content value to sectors outside battery recycled-content requirements.

    Avoid leakage of recycled-content value to sectors that are not subject to battery recycled-content requirements.

  • Ensure valid recycled-content claims do not expire solely due to administrative reasons.

    Ensure that valid recycled-content claims do not expire for purely administrative reasons.

  • Align the EU correction factor with the bottleneck of refining and upgrading materials into battery-grade chemicals in Europe.

    Align the EU correction factor with the real bottleneck in the value chain: refining and upgrading recycled materials into battery-grade chemicals in Europe.

• Europe India Centre for Business & Industry NGO, EST; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure the verification framework avoids duplicative reporting and limits data collection to what is necessary.

    EICBI recommends that the final framework focus on information that is necessary for effective verification and avoid duplicative reporting wherever possible.

• ECOS - Environmental Coalition on Standards NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Incorporate segregation or controlled blending as viable chain of custody options to enhance physical traceability.

    At the same time, ECOS regrets that segregation or controlled blending were not considered as viable Chain-of-Custody options, as such methodologies would have allowed for better physical traceability along the value chain, thus considerably reducing the risk of frauds.

  • Ensure robust enforcement and implementation mechanisms around the use of credits to avoid misleading recycled content claims.

    While the draft proposal does include toll treatment obligations to minimise the risk of loopholes, robust implementation and enforcement mechanisms will be needed to avoid inaccurate recycled content claims that may dilute the ambition of the Batteries Regulation and mislead consumers.

• BMW Group Company, DEU model reads as: supports source
  • Ensure sustainability goals are pursued efficiently regarding data collection, reporting, and verification efforts.

    At the same time, it is important that these measures help ensure that sustainability goals are pursued not only effectively but also efficiently especially regarding the efforts for data collection, reporting and verification.

• Association of Equipment Manufactures Business association, USA model reads as: wants changes source
  • Encourage harmonized requirements, protect confidential OEM data, consider operational flexibility, and use a transparent calculation methodology.

    Our feedback encourages harmonized requirements across the battery value chain, protection of confidential and commercially sensitive OEM data, consideration of operational flexibility for participants, and a transparent and consistently applied methodology for calculating recycled content.

  • Provide additional clarity and more precise definitions for key terms and concepts across the battery value chain.

    AEM also highlights the need for additional clarity and more precise definitions for certain terms and concepts, including supply chain actors, operational boundaries, restrictions, and boundary calculations, to reduce ambiguity and support consistent compliance throughout the battery value chain.

• T&E NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Phase out credit-based allocation methods in the medium term in favour of real-life traceability.

    However, in the medium term, as recycling technologies and capacity expand, T&E supports gradually phasing out credit-based allocation methods in favour of real-life traceability.

  • Include a review clause in the delegated act to assess traceability models and adapt rules based on market developments and waste availability.

    This transition should be supported by a review clause in the delegated act to assess the effectiveness of the current traceability models and allow adaptation based on market developments and waste availability.

• cylib GmbH Company, DEU; register: Companies & groups model reads as: wants changes source
  • The Commission should permit audited mass balancing at both plant and group levels.

    1. Allow audited plant- and group-level mass balance

  • The definition of the final recycling step should be established in a process-neutral manner.

    2. Define the last recycling step in a process-neutral way

  • Physical and regulatory recycled content should be documented and reported separately.

    5. Report physical and regulatory recycled content separately

• E.ON SE Company, DEU; register: Companies & groups model reads as: wants changes source
  • Clarify that downstream economic operators can rely on manufacturer-provided verified documentation without independently verifying upstream supply chains.

    To ensure consistency with the allocation of responsibilities under Union product legislation, the provision should clarify that downstream economic operators may rely on manufacturer-provided and verified information regarding recycled content, including information made available through the battery passport

  • Establish the Battery Passport as the primary source for recycled-content compliance documentation to minimize duplicate reporting.

    Consequently, we strongly support maximising the role of the Battery Passport. It should become the primary source for recycled-content information and compliance documentation to avoid duplication of reporting and administrative burdens.

• E-Mobility Europe Business association, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Consider targeted points outlined in the attached feedback without making major structural changes.

    However, we would encourage the Commission taking into account the targeted points outlined in the attached file.

• Business & Science Poland (BSP) Business association, POL; register: Trade and business associations model reads as: wants changes source
  • Link the duration and phase-out of the 1.3 correction factor directly to market maturity.

    links the duration and phase-out of the 1.3 factor to market maturity;

  • Recognise industrial by-products and process residues when they functionally substitute primary feedstock.

    recognises industrial by-products and process residues when they genuinely substitute primary feedstock;

  • Ensure robust end-to-end traceability with safeguards against double counting.

    ensures end-to-end traceability with safeguards against double counting.

• EUROBAT - Association of European Automotive and Industrial Battery Manufacturers Business association, BEL model reads as: supports source
• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Regular monitoring should be conducted to assess the effectiveness of the Delegated Act's implementation.

    highlights that its implementation should be monitored regularly to assess its effectiveness.

  • Several elements of the draft need clarification and improvement to prevent negative business impacts on recyclers.

    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.

  • Final rules must support European recycling capacity investment and maintain the value of recycled materials.

    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.

• Nickel Institute Business association, BEL; register: Self-employed individuals model reads as: wants changes source
  • Recycled content requirements should apply across all battery chemistries to ensure level competition.

    The Institute urges the Commission to extend recycled content requirements to all battery chemistries to ensure fair competition and comprehensive recycling.

  • The 1.3 correction factor should be maintained and extended to processes occurring partially outside the EU.

    The Institute also supports a correction factor of 1.3 for recycled content but suggests it be applied even when recycling processes occur partially outside the EU to reflect global operations accurately.

  • Verification procedures must ensure strict confidentiality protections for sensitive operational data.

    The Institute stresses the importance of protecting this sensitive data from being improperly shared with third parties involved in compliance verification.

• ALCOA Company, ESP model reads as: supports source
  • Require a 1-year rolling average mass balance for volumes outside specific contractual arrangements, backed by safeguards and verification.

    For the remaining volume, a 1-year rolling average mass balance should be required, together with safeguards against double counting, transparent documentation, and independent verification.

  • Prioritize physical segregation where possible.

    Where possible, physical segregation should also be prioritized.

• Battery Association for Supply Chain and Battery Association of Japan Business association, JPN model reads as: wants changes source
  • Ensure fair, transparent, and non-discriminatory treatment under the recycled content framework for trusted partner countries that have economic agreements with the EU.

    In particular, countries that share the EUs policy objectives and have established Economic Partnership Agreements (EPAs) or similar arrangements with the EU should be appropriately recognized as trusted partners and afforded fair and non-discriminatory treatment under the recycled-content framework.

• European Cycling Industries Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Address the challenges faced by light means of transport in implementing the proposed recycled content rules.

    ECI believes that LMTs face several challenges in implementing the Commission's proposal for recycled content in batteries.

• Orano Company, FRA; register: Companies & groups model reads as: wants changes source
• Micro company, CHE Academic or research institution, CHE model reads as: wants changes source
  • Clarify the treatment of recycling activities carried out in closely integrated European non-EU countries.

    first, the treatment of recycling activities carried out in closely integrated European countries outside the European Union;

  • Clarify the applicability of the methodology to other battery chemistries and critical raw materials such as LFP and graphite.

    and second, the applicability of the methodology to different battery chemistries and additional critical raw materials, particularly lithium iron phosphate (LFP) batteries and graphite.

• European Metals Business association, BEL model reads as: supports source
  • Clarify and rephrase selected sections in the draft annex to improve legal certainty and practical implementation.

    Nonetheless, European Metals considers that a number of sections within the draft annex could benefit from further clarification or rephrasing to ensure enhanced legal certainty, streamlined implementation by operators, and that the proposed methodologies support the objectives of the EU Batteries Regulation (EUBR).

• Nissan Automotive Europe Company, JPN; register: Companies & groups model reads as: supports source
• Toyota Motor Europe Company, BEL model reads as: supports source
• Fortum Battery Recycling Oy Company, FIN model reads as: supports source
  • Elements of the regulatory framework should be evaluated to safeguard a material-based business model for recycling.

    Several elements of the framework should be carefully assessed to ensure that recycling remains a material-based business model and that the value of recycled materials is preserved throughout the value chain.

  • The final rules should incentivize investment in European recycling capacity and recognize the role of recyclers and refiners.

    The final rules should support investment in recycling capacity in Europe and provide appropriate recognition for the contribution of recyclers and refiners to the circular battery economy.

• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: supports source
  • Supplement the traceability model with machine-verifiable recycled-content statements linked to authoritative source records.

    We recommend complementing this model with standardised, machine-verifiable recycled-content statements.

  • Conduct controlled cross-border pilot tests of the digital verification model prior to wider implementation.

    Controlled cross-border pilots could test this model before wider implementation.

• European Battery Recycling Association (EBRA) Business association, BEL; register: Trade and business associations model reads as: supports source