Battery recycling efficiency: what gets left out of the calculation
7 min read
The recycling efficiency percentage you are holding for 2025 does not only measure what leaves the plant: it also measures what you decided to count going in. Six elements can be kept out of the sum, the choice stays yours until 31 December 2029, and for three of them it stops on 1 January 2030. Anyone counting on the targets being pushed back has just had the answer: they are not.
On 11 September 2026 the Commission sent Parliament and Council report COM(2026) 470 final on whether those targets should be revised. The conclusion fits in one line: «Gli attuali obiettivi di cui all’allegato XII, parti B e C, del regolamento (UE) 2023/1542 rappresentano un giusto equilibrio tra ambizione e fattibilità.» — the current targets set out in Parts B and C of Annex XII strike an appropriate balance between ambition and feasibility. It is an assessment, not a legislative act: moving the targets would have taken a delegated act under Article 89, and there is none. On its own it changes nothing, but it clears away the assumption someone was planning on.
The targets do not move, and the first one has already passed
On the consolidated text as at 13 August 2026, the latest of four, Annex XII, Part B requires by 31 December 2025 recycling of 75 % by average weight of lead-acid batteries, 65 % of lithium-based batteries, 80 % of nickel-cadmium and 50 % of other waste batteries; by 31 December 2030, 80 % for lead-acid and 70 % for lithium. Part C requires by 31 December 2027 material recovery of 90 % for cobalt, copper, lead and nickel and 50 % for lithium; by 31 December 2031, 95 % for the first four and 80 % for lithium. The first deadline passed nine months ago, and Article 71(2) puts the obligation on recyclers.
The first formal figure, however, has yet to move: the report places recyclers’ reporting to competent authorities by mid-2027 and that of Member States by mid-2028 (Article 75(7) and Article 76(1)). The year now ending is the first that will be written down in a verified document.
Six elements, two regimes, one date
The method is Commission Delegated Regulation (EU) 2025/606 of 21 March 2025 (OJ L, 4.7.2025): efficiency is the ratio between the mass of the output fractions and the mass of the input fractions, per calendar year and per chemistry. Hence the arithmetic that matters: an element counted going in but not recovered sits in the denominator without appearing in the numerator, and pushes the result down. The composition of the input fraction can also be derived from the battery passport.
Point (5) of the Annex provides that until 31 December 2029 oxygen, carbon from carbon sources at cell level, iron from iron sources at cell level, phosphorus, chlorine and sulphur «possono essere considerati» — may be taken into account — in both m input and m output. Point (6) changes the verb: from 1 January 2030 carbon, iron and phosphorus «sono considerati», shall be taken into account, while for oxygen, chlorine and sulphur inclusion «diviene facoltativa», becomes optional.
May against shall: today the six elements are optional and the plant chooses; from 2030 three enter both sides of the ratio automatically and three stay optional. The strict regime starts on 1 January 2030 and the 70 % lithium figure is measured on 31 December 2030: the target year is the first year of the new method. And Article 71(5) sets the rhythm of the review: «Entro il 18 agosto 2026 e successivamente almeno ogni cinque anni», by 18 August 2026 and at least every five years thereafter. The next obligatory review falls no later than 18 August 2031.
The word the regulation does not contain
The report states that from 1 January 2030 it will no longer be possible to exclude from the calculations «i solventi e la grafite (e più in generale le frazioni di carbonio)» — solvents and graphite (and more generally carbon fractions) — and later that «la grafite, il ferro e il fosforo» will have to be included in the calculations.
In the delegated regulation, though, «grafite» never appears: zero occurrences in Italian and zero in English. Nor does «solventi». «Carbonio» appears twenty-eight times, always in the formula «carbonio proveniente da fonti di carbonio a livello di elemento» — carbon from carbon sources at cell level — or in the note that lists recycled plastic separately from carbon at cell level.
That is not a contradiction: graphite is carbon, and the anode is a cell-level source. It is a difference you feel when filling in the forms: the Annex templates carry a line for carbon from carbon sources at cell level, not one for graphite. Anyone who built their data structure on the language of the report is hunting for a field that does not exist; anyone who built it on the regulation has to know that, on the Commission’s reading, solvents end up in that same line.
Three calculation models, three outcomes
The Joint Research Centre estimated the achievable weighted average efficiency for lithium-based batteries under three models: no exclusion of fractions; exclusion of oxygen only, with graphite and solvents treated as recovered; exclusion of oxygen, solvents and graphite. Same plants, same year, three percentages and three outcomes.
With no exclusions, «conseguire gli obiettivi sarebbe molto difficile nel caso di tutte le batterie al litio, a meno che non siano recuperate ulteriori frazioni (ad esempio la grafite)» — reaching the target would be very difficult in the case of all lithium-based batteries, unless additional fractions are recovered, graphite for instance. With oxygen alone out, 2025 could be missed because graphite and solvents are counted in the input received but in practice not yet recycled at a sufficiently high rate. With all three out, the model would make it possible to reach the 2025 and 2030 targets for lithium-based batteries.
The 50 % lithium recovery target for 2027 also stays: rather than being the maximum currently reachable in terms of technological feasibility and economic profitability, the report says, it is considered well balanced. Lowering it could delay necessary investments in battery recycling, and any decrease would also apply to recycling in non-EU countries following Article 72(3).
What we do not know
The JRC analysis is forward-looking modelling and the report states its limits: it relies on assumptions and estimations, as is the case with any modelling activity. The composition of the waste available is estimated with a Weibull distribution and much of the data submitted by industry was confidential. The percentages for the three models sit in a figure, not in the text: we do not report them. We do not know what any individual plant does and we do not write it — public data measure outcomes, not processes. Many stakeholders called the assessment premature; none asked for its conclusions to be changed.
The two axes, applied
Complying. The register you need is not a sheet with a percentage at the bottom. It holds together, per calendar year and per chemistry, the input fractions with their sorting analysis, the intermediate ones, the output ones and, element by element, the calculation regime chosen among those allowed until 2029. In our system that register is a control running over weighbridge data and process documents: it recalculates the ratio under both assumptions and flags which flows would already hold up under the 2030 method. Verification is annual, and the regulation is explicit — «non sono escluse le visite presso gli impianti di riciclaggio», visits to recycling facilities are not excluded as part of the auditing procedure.
Deciding. The same system holds weighbridge records, laboratory analyses, waste transport forms and export evidence together in a single operating model, on which AI agents run the calculation, the reconciliation and the preparation of the file, with an operator in command who approves or corrects. For large enterprises, defence, public administration and healthcare, from manufacturing to waste operators. Always in two delivery modes: on-premise on standalone machines that require no deep integration into the client’s network, or dedicated cloud with a dedicated VPN and data centres in Italy, always with shared management.
From the first session, at no cost, you get the dated double calculation: your rate under today’s method and under the 2030 one, plus the fractions where the difference is decided. It stays with you even if we do not carry on together. Talk it through with one of our engineers.