EU battery-recycling accounting connects inputs, outputs and intermediate materials
EU rules treat black mass as an intermediate and specify information for recycling-efficiency and material-recovery accounting.
Source facts
Delegated Regulation (EU) 2025/606 harmonises calculation, verification and documentation of recycling efficiency and material recovery. Records cover chemistry-specific inputs, process flows, intermediate fractions, outputs, destinations and yields. Black mass is an intermediate; its metals require further processing before counting towards material recovery.
Article 77 of Regulation (EU) 2023/1542 separately requires battery passports from 18 February 2027 for LMT batteries, industrial batteries with capacity greater than 2 kWh, and EV batteries placed on the EU market or put into service. This concerns the specified batteries, not every Chinese project or recycling machine.
