Recycled content evidence: chain of custody, mass balance and verification for recovered materials

Recycled content evidence is the chain of records that supports a declared share of cobalt, lead, lithium or nickel recovered from waste. The chain has three links: chain of custody from waste collection and treatment to the material input, mass balance calculation that converts material flows into a share for the battery model, and verification that checks the calculation and the custody records against the methodology. A declared share without that chain is an assertion.

A certificate without the chain is a document that asserts a result without showing how the result was reached. Evidence discipline requires all three links to be present, identifiable and checkable, for each material separately.

What is chain of custody for recovered material?

Chain of custody is the documented sequence of custody for recovered material, from the point at which waste is collected and treated, through recovery and refining, to the point at which the recovered material enters battery production. The chain identifies the waste source type, the treatment and recovery facility type, the material form at each transfer, and the mass transferred. Chain of custody does not need to identify every individual waste battery, which would be impractical at scale. It needs to identify the system by which recovered material is kept separate from virgin material, or mixed under controlled mass balance rules, so that the share claimed for the output can be traced to recovered inputs. A chain that shows only the final supplier, without the recovery route, is incomplete. A chain that shows a recovery route without masses is a narrative, not a custody record.

How does mass balance work for recycled content?

Mass balance is an accounting method in which recovered and virgin inputs to a process are tracked by mass, and the output is allocated a recycled share based on the proportion of recovered input, under rules that prevent double counting and that define the period and the system boundary. Mass balance allows recovered material to be mixed with virgin material in a process, provided the accounting is controlled and the output claim does not exceed the recovered input in the defined period and system. Mass balance is not physical segregation, and a mass balance share does not prove that the specific atoms in a specific battery came from waste. The declaration should state that the share is calculated by mass balance where that is the method, so that a reader does not mistake an accounting share for a physical trace. The calculation record should show inputs, outputs, period, system boundary, and the allocation rule, so that the share can be repeated from the inputs.

What does verification check?

Verification checks the calculation, the custody records and the application of the methodology, by a verifier or notified body as the delegated act requires. Verification checks that the masses reconcile, that the custody system operates as described, that the period and scope match the declaration, and that the share was calculated by the prescribed method. Verification does not check every transaction in the chain. It checks the system, the records and a sample of transactions, and it reports the result for the period and scope verified. The passport record should reference the verification position: the verifier type, the date, the period and scope, and the outcome in neutral terms. A verification reference without a period or scope cannot be matched to a declaration for a different period. A declaration that cites verification for a different model, plant or period is unverifiable for the model in front of the reader, and the evidence trace should say so.

What does the evidence table illustrate?

How are evidence gaps handled?

An evidence gap, such as a missing custody record for a period, a mass balance that does not reconcile, or a verification that does not cover the declared period, is recorded as a gap with the material, the period and the remedy stated. The gap is not filled by a supplier assurance, a general certificate, or a share from another period. A supplier assurance can be part of the evidence, but it cannot replace custody and calculation records. A general certificate that covers a material family cannot support a share for a specific model and plant without a link showing that the model and plant fall within the certificate scope and period. Gaps in recycled content evidence are common where recycling supply chains are new, and honest gap reporting is more useful than a complete looking declaration built on incomplete evidence.

What must recycled content evidence never claim?

Evidence for a recycled share must never claim that the specific battery contains atoms recovered from waste, that the material is traceable to a single waste source, or that the share proves a circular or sustainable outcome. Mass balance shares are accounting claims, and the record must present them as such. This guide gives general educational information only and does not give legal advice for a particular battery, material or transaction.