Recycled shares for cobalt, lithium, nickel and lead: reading the four percentages together

Recycled content shares are stated for four materials: cobalt, lead, lithium and nickel. Each share is a separate claim, calculated separately, with a separate supply chain, a separate recycling route, and a separate minimum threshold in Article 8. Reading the four shares together, as if they were four parts of one claim, misleads in both directions: a high share for one material can hide a low share for another, and a low share for a material present in small amounts can be mistaken for a failure of circularity for the battery as a whole.

The correct reading is material by material, with the mass, the share, the method and the threshold for each material stated alongside the figure.

What are the minimum percentages?

Article 8 sets minimum percentage shares of recycled content for industrial batteries, EV batteries and SLI batteries in scope. From 18 August 2031, the minimums are 16 percent for cobalt, 85 percent for lead, 6 percent for lithium and 6 percent for nickel. From 18 August 2036, the minimums are 26 percent for cobalt, 85 percent for lead, 12 percent for lithium and 15 percent for nickel. LMT batteries join the minimums on a later timetable, as Article 8 provides. The minimums are subject to amendment by delegated act under Article 8(5), where the Commission assesses the availability of recovered material and market developments. A record that states a minimum as if it were a current declared share, or that states a declared share as if it met a future minimum, confuses a threshold with a measurement. Thresholds are future requirements. Shares are current declarations. The two belong in separate fields, with separate dates.

Why is lead different from the other three?

Lead shows a high minimum, 85 percent in both periods, because lead acid battery recycling is long established, collection and recovery routes are mature, and recovered lead is routinely reused in new lead batteries. Cobalt, lithium and nickel show lower minimums, because lithium based battery recycling at scale is newer, recovery of lithium in particular has been technically and economically challenging, and the supply of recovered material is still developing. The difference is a statement about recycling systems, not about the importance of the materials. A reader who expects all four shares to be similar will misread a record in which lead is high and lithium is low. The record should allow the reader to see the system context in the threshold, without presenting the threshold as an explanation for a particular declared share. A declared share is a fact about a model. A threshold is a requirement for the future. The gap between the two is a planning fact, not a judgement on the model alone.

How should the four shares be compared across batteries?

Comparison across batteries requires the same material, the same calculation method, the same scope, and the same period. A cobalt share calculated for one model and plant, in one period, cannot be compared with a cobalt share calculated for another model, by another method, in another period, without a method note. Comparison should also consider absolute mass: a high share of a material present in small mass is a different circularity fact from a moderate share of a material present in large mass. The table below shows the reading structure. Illustrative labels mark positions, not declared shares for a real battery.

What do the shares not show?

The shares do not show where the recovered material came from, how it was recovered, what the recovery process emitted, or whether the material will be recovered again at end of life. Origin, recovery process and future recyclability are separate fields with separate evidence. A high recycled share does not prove low carbon, responsible sourcing, or future recycling. A low share does not prove poor design, because the availability of recovered material varies by material, by region and over time. The shares are one input to a circularity assessment, not the assessment itself. A reader who treats the four percentages as a circularity score overreads the declaration.

How should a reader record a share that has changed?

A share that has changed since a previous declaration should be recorded as a change, with the old share, the new share, the date, and the reason in neutral terms, such as a change in supplier, a change in calculation method, or a change in the period covered. The change record should state whether the change reflects a real change in recovered material use or a change in method or scope, because the two have different meanings for a reader comparing models over time. A share that rises because the method changed is not evidence that circularity improved. A share that falls because the scope widened is not evidence that circularity worsened. The passport entry should show the current share, and the version history should show the sequence, so that a reader comparing a current entry with an older screenshot can explain the difference from the record alone.

How are the shares linked to critical raw materials policy?

Cobalt, lithium, nickel and manganese in battery grade forms are listed as strategic raw materials under Regulation (EU) 2024/1252, the Critical Raw Materials Act, which sets benchmarks for extraction, processing and recycling capacity in the Union. Recycled content shares in the Battery Regulation and recycling capacity benchmarks in the Critical Raw Materials Act point in the same direction, more recovered material reused in new batteries, but they are different instruments with different duties. The passport record shows the Battery Regulation shares. It does not show compliance with Critical Raw Materials Act benchmarks, which are Union level capacity goals, not battery level duties. Conflating the two instruments misstates both. This guide gives general educational information only and does not give legal advice for a particular battery, material or transaction.