Battery Recycling in the EU and Germany: Why High-Quality LCA Data Has Become the Backbone of Compliance

EU battery rules require recycling targets, carbon data and digital passports.

Jan 13, 2026

EU Battery Regulation Explained: Data, Carbon Footprints, and Compliance

The European battery sector is entering a transformative decade. With the introduction of the new EU Battery Regulation (Regulation (EU) 2023/1542), the entire lifecycle of batteries — from design and manufacturing to collection, recycling, and data reporting — is now governed by an ambitious circular-economy legislation. Unlike previous directives, this regulation applies directly in all EU Member States without the need for national transposition, creating a unified, binding framework that sets mandatory targets for collection, recovery efficiency, and minimum levels of recycled content. This direct applicability marks a major shift toward consistent enforcement and shared standards across the European market.

At the center of these regulatory changes lies one critical component: reliable and verifiable environmental data. Life Cycle Assessment (LCA) and CO₂e values have become indispensable tools for demonstrating compliance, verifying recycled material content, ensuring transparency, and enabling digital product passports and carbon footprint declarations. Without high-quality CO₂e data, companies simply cannot meet the obligations defined within the new EU framework.

A New Era of Battery Governance: EU Battery Regulation and the German BattDG

The EU Battery Regulation marks a fundamental shift from earlier legislation by introducing binding, directly applicable rules across all member states. Unlike the 2006 directive it replaces — a framework that focused mainly on basic collection targets, substance restrictions, and general take-back obligations and had to be transposed into national law — the new regulation sets clear sustainability and performance requirements that apply to every stage of a battery’s life. It introduces mandatory carbon-footprint declarations, minimum levels of recycled content, new design requirements for removability, and ambitious collection and recycling targets. By covering the entire lifecycle — from design and market placement to end-of-life treatment and data reporting — the regulation establishes a unified framework that transforms batteries into fully traceable and circular products.

Key Targets and Implementation Deadlines

Building on these overarching requirements, the EU Battery Regulation sets out a detailed timeline of obligations that will take effect over the coming years. The regulation specifies measurable collection targets, recovery-efficiency benchmarks, carbon-footprint obligations, and transparency rules to ensure continuous progress across the battery value chain.

For portable batteries, collection rates must rise to 63 percent by 2027 and further increase to 73 percent by 2030, while light transport batteries must reach a collection rate of 51 percent by 2028 and 61 percent by 2031. From 2027 onward, recyclers will also need to meet ambitious material recovery-efficiency thresholds, achieving at least 90 percent for cobalt, nickel, copper, and lead, and improving lithium recovery to 80 percent by 2031. Beginning in 2031, batteries placed on the EU market will have to contain minimum levels of recycled content, including 16 percent cobalt, 6 percent lithium, 6 percent nickel, and 85 percent lead. In addition, carbon-footprint declarations will become mandatory from 2025 for Electric Vehicle (EV) and industrial batteries, requiring manufacturers to provide standardized cradle-to-gate CO₂ data.

By 2027, all batteries with a capacity of 2 kWh or more must be accompanied by a digital battery passport documenting their composition, carbon footprint, and recycled-material content. At the same time, design rules will require that portable batteries be user- or service-removable by 2027, reinforcing the regulation’s emphasis on circularity, accessibility, and improved end-of-life management.

Germany’s National Implementation: The BattDG as the Legal Framework for Market Access

While the EU Battery Regulation applies directly across all Member States, national legislation defines how these rules are operationalized and enforced. In Germany, this role is fulfilled by the Battery Law Implementation Act (BattDG), which entered into force on 7 October 2025, replacing the former Battery Act (BattG) and formally embedding Regulation (EU) 2023/1542 into national law. The BattDG introduces significant changes for manufacturers, importers, and distributors, reshaping the German market’s governance structure for battery compliance.

The objective of the BattDG is to strengthen resource efficiency and circularity in the battery sector, expand and clarify producer responsibility, and ensure harmonized, transparent systems for the collection, take-back, and recycling of all battery types. One of the most substantial structural changes is the transition from the previous three battery categories to a new system of five categories: starter batteries, industrial batteries, portable batteries, electric-vehicle batteries, and batteries for light means of transport (LM batteries). This reclassification enhances traceability and ensures that responsibilities and reporting obligations are tailored to the specific risk profiles and material compositions of each category.

To place batteries on the market, manufacturers and importers must register with Stiftung Elektro-Altgeräte Register (EAR). Batteries may only be supplied if they are correctly registered. As of 1 January 2026, participation in an authorized Organization for Producer Responsibility (OfH) becomes mandatory for every battery category. These OfHs require formal approval from Stiftung EAR, ensuring a controlled, transparent, and accountable system for financing collection, transport, and recycling. Foreign companies without a registered office in Germany must appoint an authorized representative based in Germany to fulfill their regulatory duties.

What companies must do under the BattDG

Register with Stiftung EAR before placing batteries on the German market.
Join an authorized Organization for Producer Responsibility (OfH) to finance and fulfill collection and recycling obligations.
Submit regular reports on battery quantities, collection outcomes, and recovery performance.
Ensure compliance, as failure to meet regulatory obligations may result in penalties or direct market restrictions.

Extended Producer Responsibility: Linking Compliance, Cost, and Circularity

A central pillar of the EU Battery Regulation is the principle of Extended Producer Responsibility (EPR), which fundamentally reshapes how battery producers operate within the European market. Under EPR, manufacturers become both legally and financially accountable for the entire life cycle of the batteries they introduce to the market — from initial market placement to end-of-life collection, transport, and recycling. This means that companies must not only finance these activities but also ensure that they are executed effectively and in full alignment with regulatory requirements. EPR also requires producers to maintain detailed documentation on the quantities of batteries placed on th emarket, returned, and recycled, enabling regulators to verify compliance with collection targets and material recovery efficiencies. To support safe and responsible disposal, producers must also provide clear labelling and consumer information. By tying financial responsibility directly to environmental performance, EPR creates strong incentives for eco-design, enhanced durability, and greater circularity across the battery value chain.

Practical implications of EPR for battery producers

Financial Responsibility: Producers must organize and fund the collection, transport, and recycling of batteries at end of life.
Data Reporting: Companies are required to report accurate data on the quantities of batteries placed on the market, collected, and recycled.
Performance Standards: Producers must ensure that contracted recyclers meet the mandated material recovery-efficiency targets.
Consumer Information: Clear labelling and disposal instructions must be provided to support safe and compliant end-of-life management.

Types of Batteries and Their Recycling Value

Understanding the chemistry and material composition of different battery types is essential, as recycling technologies, recovery efficiencies, and overall economic value vary widely across chemistries. Lithium-ion batteries, lead-acid systems, nickel-cadmiumcells, and LFP batteries each contain distinct metals and materials that determine how they are processed, which recovery technologies are used, and how valuable the reclaimed materials are in circular battery markets. These differences are directly linked to regulatory requirements, particularly as the EU Battery Regulation mandates specific recovery efficiencies and recycled-content thresholds for key metals.

Lithium-ion batteries contain lithium, cobalt, nickel, manganese, and graphite —materials with high strategic and economic value. Their recycling focuses on recovering these critical metals, and lithium recovery is now legally mandated due to their central role in EVs and energy-storage applications.

Lead-acid batteries primarily consist of lead and operate within a well-established closed-loop system. Their recycling process is highly mature, achieving recovery efficiencies of around 95 percent, making them one of the most successfully recycled battery types globally.

Nickel-cadmium batteries contain nickel and cadmium. Recycling priorities center on recovering cadmium with high efficiency (up to 95 percent), but strict handling and safety requirements apply due to cadmium’s toxicity.

LFP (Lithium Iron Phosphate) batteries use lithium, iron, and phosphorus and do not contain high-value metals such ascobalt or nickel. Although their economic recycling value is lower, they play a vital role in sustainable battery markets because of their safety, long cycle life, and importance in stationary storage and entry-level EV applications.

How Battery Recycling Works: Key Steps in the Circular Battery Value Chain

Battery recycling follows a structured, multi-stage process that determines how effectively critical raw materials can be recovered and reintroduced into new battery production. Understanding these steps is essential, as each phase generates specific material flows and emissions that must be documented under the EU Battery Regulation and traced within the digital battery passport.

The process begins with collection and safe handling, where batteries are gathered under Extended Producer Responsibility systems and discharged to prevent thermal orchemical hazards. Under the EU Battery Regulation, most portable batteries must be designed to be easily removable from 2027 onward, ensuring that collection, sorting, and initial treatment can be carried out more safely and efficiently. Once collected, batteries undergo mechanical pre-treatment, a stage in which devices are dismantled or shredded to produce various output fractions, including the highly valuable “black mass” — a concentrated mixture of lithium, cobalt, nickel, manganese, graphite, and electrolyte residues.

The next stage is metallurgical recovery, where this black mass is processed to extract high-purity materials. Pyrometallurgy, a smelting-based approach, reliably recovers metals such as cobalt, nickel, and copper, but offers limited lithium recovery and is energy-intensive. Hydrometallurgy, in contrast, uses aqueous leaching to separate and purify metal salts with higher lithium yields, making it increasingly important for meeting the EU’s mandatory recovery-efficiency targets. A third pathway, direct recycling, is emerging as a low-carbon solution capable of restoring cathode materials to near-original performance with significantly reduced environmental impact.

In the final stage, refined materials are converted into battery-grade compounds such as lithium carbonate (Li₂CO₃), cobalt sulfate (CoSO₄), and nickel sulfate (NiSO₄). These materials can then re-enter cell manufacturing, enabling a true closed-loop system that reduces dependency on primary raw materials and lowers the overall carbon footprint of battery production.

The Critical Role of Data: Carbon Footprints, LCA, and Compliance

The EU Battery Regulation turns battery recycling into a fully data-driven accountability system, requiring every industrial and EV battery to be accompanied by a carbon-footprint declaration and a digital battery passport that documents material composition, recycled content, sourcing, and environmental performance. These obligations rely on Life Cycle Assessment (LCA), the standardized method used to quantify environmental impacts from raw material extraction through manufacturing, use, and end-of-life recycling. LCA data is essential for demonstrating cradle-to-gate CO₂e values, verifying mandatory recycled-content thresholds — such as 6% lithium, 16% cobalt, and 6% nickel — identifying environmental hotspots, and improving energy and recovery efficiency within recycling processes. It also provides the traceability and verification needed to ensure that battery-passport data is credible and aligned with regulatory expectations. In this new circular battery economy, accurate and high-quality CO₂e data is no longer optional; it is the foundation of compliance, transparency, and competitive differentiation.

From Regulatory Obligation to Circular Leadership — How Sustamize Enables Battery Regulation Compliance

As the EU Battery Regulation and Germany’s BattDG introduce mandatory rules for design, collection, recovery efficiency, carbon-footprint reporting, and digital battery passports, companies face a rapidly expanding set of data and documentation requirements. Producers must register with Stiftung EAR, join an authorized producer responsibility organization, ensure design compliance for removability and labelling, collaborate only with certified recyclers that meet legally defined recovery thresholds, and maintain complete datasets on weights, chemistries, yields, and emissions. In addition, lifecycle data must be calculated using standardized EU templates, supported by credible third-party verification before being included in public disclosures or battery-passport submissions. Meeting these requirements demands a robust, transparent, and scalable data infrastructure.

This is where sustamize becomes an essential partner. We help companies navigate the complexity of the EU Battery Regulation with precise, verifiable, and digital-ready CO₂e data at material and process level, supporting transparent carbon accounting across the battery lifecycle. Our scientifically validated emission datasets enable manufacturers, recyclers, and supply-chain partners to generate accurate Product Carbon Footprints (PCFs) for battery materials and components, aligned with ISO 14067 and the GHG Protocol. Expanding coverage toward more comprehensive battery system representation is a defined milestone on our 2026 roadmap. With standardized, machine-readable sustainability data, companies can prepare for the 2027 rollout of the digital battery passport, ensuring that carbon footprints, material compositions, and recycled-content declarations are complete, consistent, and audit-ready.

Beyond compliance, sustamize provides lifecycle optimization insights that reveal carbon hotspots, material inefficiencies, and opportunities for process improvement — supporting not only regulatory readiness but also operational excellence and circular transformation. Through our Product Footprint Engine, organizations can automate complex sustainability data workflows, streamline CSRD and Scope 3 reporting, and integrate battery-regulation requirements directly into product development and supply-chain processes. The result is a scalable, transparent system that turns CO₂e into actionable intelligence for compliance, competitiveness, and long-term sustainability leadership.

This foundation is further strengthened by sustamize’s recycling emission factors. Driven, among other factors, by evolving regulatory requirements such as the EU Battery Regulation, sustamize continuously expands its data coverage. As part of this ongoing development, over 100 new recycling emission factors are being added to our material database. These additions further support consistent modeling of recycled content and end-of-life impacts and enable transparent, regulation-aligned carbon accounting.

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