Recycled content is the part of a product that comes from materials recovered from waste instead of newly extracted raw materials. It is normally given as a percentage by weight, such as "30% recycled polyester" or "16% recycled cobalt in active materials".
EU rules are moving recycled content from a marketing claim to a regulated figure. Some products now have legal minimums, others must disclose the share, and in both cases the number has to be calculated and proven with a defined method.
Types of recycled content
- Post-consumer: material from products that people used and discarded, such as bottles collected for recycling.
- Pre-consumer or post-industrial: waste from manufacturing, such as offcuts or rejected parts, that would otherwise be thrown away.
- Not recycled content: scrap reused within the same process, which never became waste.
Which types count depends on the rule. EU packaging targets count only post-consumer plastic. The battery targets count both battery manufacturing waste and post-consumer waste, but exclude by-products reused in the same process.
EU recycled content rules
Batteries. Article 8 of the EU Battery Regulation covers industrial batteries above 2 kWh (except those with exclusively external storage), electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials:
| From | Cobalt | Lead | Lithium | Nickel |
|---|---|---|---|---|
| 18 August 2031 | 16% | 85% | 6% | 6% |
| 18 August 2036 | 26% | 85% | 12% | 15% |
Before the minimums apply, these batteries must carry documentation of their recycled content per model, per plant and per year, from 18 August 2028 or 24 months after the Commission adopts the calculation method, whichever is later. Light means of transport batteries follow later. The share also appears in the battery passport.
Plastic packaging. Article 7 of the Packaging and Packaging Waste Regulation (EU) 2025/40 sets minimum post-consumer recycled content for each plastic part of packaging, calculated per manufacturing plant and year:
| Packaging type | By 2030 | By 2040 |
|---|---|---|
| Contact-sensitive, PET | 30% | 50% |
| Contact-sensitive, other plastics | 10% | 25% |
| Single-use plastic beverage bottles | 30% | 65% |
| Other plastic packaging | 35% | 65% |
The 2030 date is 1 January 2030 or 3 years after the Commission's calculation method enters into force, whichever is later. Some packaging, such as medical and compostable packaging, is exempt.
ESPR products. The Ecodesign for Sustainable Products Regulation (ESPR) lists recycled content among the parameters that delegated acts can turn into information requirements or minimums. Where they do, it goes into the Digital Product Passport. Textiles, furniture and mattresses are among the priority groups in the working plan.
France. Under the AGEC law, larger brands selling in France must state the share of recycled material in an online product sheet.
How recycled content is measured and proven
Recycled content is only as good as its paper trail. Common approaches:
- Segregation: recycled material is kept physically separate through the chain.
- Mass balance: recycled and virgin material mix, and the recycled share is tracked by bookkeeping.
- Certificates and declarations from recyclers and suppliers, often under recognized certification schemes.
For batteries and packaging, the EU sets the calculation and verification method in secondary legislation, and the results become part of the technical documentation. Signed supplier data, for example as a verifiable credential, makes each claim easier to check.
How to prepare
- Identify which products and packaging fall under a minimum or a disclosure duty.
- Ask suppliers for recycled content per material, with the method and certificates behind it.
- Calculate the share per model and keep the evidence on file.
- Use recycled content where it also lowers your product carbon footprint and EPR fees, which can be modulated by recycled content.
How Veribl helps
Veribl asks suppliers for recycled content, material composition and certificates through the supplier portal. Answers are signed and kept as sent, certificates issued as verifiable credentials have their signature checked, and the figures flow into each product's Digital Product Passport.
See the Veribl supplier portalOfficial sources
Frequently asked questions
What is the difference between pre-consumer and post-consumer recycled content?
Pre-consumer (or post-industrial) recycled content comes from waste generated during manufacturing, such as offcuts. Post-consumer recycled content comes from products that consumers used and threw away. EU packaging targets count only post-consumer plastic waste, while the battery targets count both battery manufacturing waste and post-consumer waste.
What are the EU recycled content targets for batteries?
From 18 August 2031, industrial batteries above 2 kWh (except those with exclusively external storage), electric vehicle batteries and SLI batteries must contain at least 16% recycled cobalt, 85% lead, 6% lithium and 6% nickel. From 18 August 2036 the levels rise to 26% cobalt, 85% lead, 12% lithium and 15% nickel, and LMT batteries are added. Documentation of recycled content is required earlier, from 18 August 2028 or 24 months after the Commission's calculation method is adopted, whichever is later.
What are the EU recycled content targets for plastic packaging?
By 1 January 2030, or 3 years after the Commission's calculation method enters into force if later, plastic parts of packaging must contain 30% post-consumer recycled content for PET contact-sensitive packaging, 10% for other contact-sensitive plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. By 2040 the targets rise to 50%, 25%, 65% and 65%.
How do you prove recycled content?
With a chain of documentation from the recycler to the final product: supplier declarations, certificates from recognized schemes, and a calculation method such as mass balance or segregation. EU rules require the calculation and verification to follow methods set by the Commission, and some require third-party verification.
Is recycled content part of the Digital Product Passport?
Yes, where the rules ask for it. The battery passport includes the recycled content share, and ESPR lists recycled content among the parameters delegated acts can require for each product group.
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