The Commission’s assessment shows that modifying lithium recovery targets would have a limited effect on European supply. Developing processes on an industrial scale remains difficult, while mandatory reporting by recyclers and Member States under the current regulation will only begin in 2027 and 2028.
The European Commission considers that the EU targets for recycling battery waste and recovering the materials it contains should be maintained. Its assessment indicates that, in the case of lithium, a more important issue than adjusting the mandatory percentages is the total treatment capacity available in the Union. Recovery processes must be developed on an industrial scale, and higher targets would, according to the modelling presented, bring only a limited gain for European supply.
In brief
1. The Commission is not proposing changes to the targets for recycling efficiency and material recovery from battery waste. For lithium, the recovery thresholds remain at 50% by the end of 2027 and 80% by the end of 2031.
2. The percentages measure different things: recycling efficiency concerns the battery mass, while recovery is calculated for each material concerned. Battery composition and the proportion of the casing influence how difficult it is to meet the overall recycling target.
3. Modelling indicates that higher or lower lithium recovery targets would have a limited effect on EU supply. The estimates include primary production and recycling, but do not take into account the available treatment capacity.
4. The first mandatory reports from recyclers are expected in 2027, followed by those from Member States in 2028. The current assessment does not demonstrate that all operators are complying with the targets; the next review is scheduled for no later than 18 August 2031.
The report examines two different obligations. Recycling efficiency measures the proportion of the mass of batteries that is recycled: for lithium-based batteries, the threshold is 65% from the end of 2025 and rises to 70% by the end of 2030. Material recovery, referred to in legislation as “material valorisation”, concerns each material concerned separately. For lithium, at least 50% must be recovered by the end of 2027 and 80% by the end of 2031. For cobalt, copper, lead and nickel, the thresholds are 90% and 95%, respectively, at the same two deadlines.
Achieving these results also depends on the battery entering the facility. Nickel-manganese-cobalt batteries contain valuable materials that support the economic viability of recycling; lithium-iron-phosphate batteries contain fewer such materials. The casing also matters: in a battery pack for an electric vehicle, recovering it with low losses can improve the result calculated for the entire pack. In portable battery cells, where the casing is smaller, losses from treating the cell carry proportionally more weight. These differences explain why the same target may be more difficult for some recyclers, the report states.
In addition, the methodology allows certain unrecovered fractions to be excluded from the recycling-efficiency calculation until the end of 2029. From 2030, graphite, iron and phosphorus must be included, which encourages the development of their recovery. This temporary flexibility changes the calculation of the indicator; it does not mean that the excluded materials have actually been recycled.
For lithium, the difficulty lies in moving from technical performance to commercial operation. According to industry information cited in the report, at the end of 2025 very few recyclers were able to recover lithium, and many processes in the EU were still at pilot scale. The lack of economies of scale, investment uncertainty and energy and labour costs higher than in third countries make sector development more difficult. The Commission considers that the 50% threshold for 2027 leaves time to optimise and expand processes. For nickel and cobalt, however, some consultation participants consider that the 95% target for 2031 is approaching the technical limit, especially in continuous production on a large scale.
Modelling carried out by the Commission’s Joint Research Centre (JRC) shows how little a change in lithium targets would alter supply. An increase or decrease of ten percentage points in recovery rates would change the share of demand covered by EU production by around two percentage points in 2027 and three in 2035. In the baseline scenario, European production could cover 18% of battery-lithium demand in 2027 and 42% in 2035. These figures include both primary production and material recovered from batteries and manufacturing waste. They are potential estimates that do not take into account the available treatment capacity, and are not results already achieved by recyclers.
“The challenge facing the EU concerns the total treatment capacity available in the EU more than the efficiency of individual treatment facilities,” the Commission states in the report. The institution considers that raising the targets could burden operators at the beginning of their activities, with limited effect on supply. Reducing them, by contrast, could discourage investment in recovery technologies and weaken recycling’s contribution to lithium supply.
The assessment has data limitations. It is based, among other things, on an industry consultation launched in September 2025, with responses coming mainly from the lithium-battery sector and with considerable confidential information. Some participants considered the analysis premature: the first reports from recyclers under the current regulation to national authorities are expected in mid-2027, while Member States’ reports to the Commission are expected in mid-2028. The conclusion to maintain the targets therefore does not represent verification that all operators are already complying with them.
The Commission does not consider the adoption of a delegated act to modify the targets justified following this assessment. The next review must be carried out no later than 18 August 2031, by which time the data reported under the current obligations should also be available.
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