Senseible

What recycled content will EU battery buyers ask Indian suppliers to document, and from when?

Under Article 8 of the EU Batteries Regulation, EV, SLI and industrial batteries above 2 kWh will need documented shares of cobalt, lead, lithium and nickel recovered from waste, per battery model and plant, from 18 August 2028 or later once the calculation rules are adopted. Minimum shares follow from 2031 and rise in 2036.

Which batteries and metals are covered

The dates and minimum shares in Article 8

The Commission reviews the targets and can amend the 2036 shares, so check the consolidated text before you commit to a supply plan.

What an Indian supplier should start keeping

  1. For each battery model and each plant, the mass of cobalt, lead, lithium and nickel in the active materials.
  2. For each lot of recycled input, the recycler, the waste source (manufacturing scrap or post-consumer) and the metal content.
  3. Chain of custody records linking recycled lots to production batches, in the form the delegated act sets once adopted.
  4. Purchase invoices and certificates from recyclers, including authorisation under India's Battery Waste Management Rules 2022 where they apply.

How this links to the battery passport and footprint

Recycled content is one of the data points the battery passport will carry, and recycled metal also tends to lower the battery's carbon footprint. Keep one set of lot level records so the same numbers feed both, rather than separate spreadsheets for each buyer request.

What Senseible does here

Senseible reads purchase invoices for metals, recycled inputs and plant energy into one dated record per site, which helps when a buyer asks for input data. The recycled content share itself comes from your material and chain of custody records.

Sources: Regulation (EU) 2023/1542 (Batteries Regulation), Article 8, recycled content, consolidated text on EUR-Lex, Battery Waste Management Rules 2022, MoEFCC

Last reviewed 2026-10-18. Checked 18 October 2026: Article 8 dates and 2031 and 2036 shares confirmed; the delegated act on calculation and verification was at draft stage (feedback closed 9 September 2026). Recheck once it is adopted, since a late adoption moves the documentation date.