EUROBAT Feedback — Public Consultation on Article 8 Recycled Content Delegated Act (Regulation (EU) 2023/1542)
EUROBAT welcomes the opportunity to comment on the draft delegated act adopted pursuant to Article 8 of Regulation (EU) 2023/1542. We appreciate the Commission's work and note that the proposed methodology is broadly aligned with the principles discussed during the JRC consultation, particularly as regards mass-balance accounting and documentation-based traceability. EUROBAT’s comments are targeted and constructive.
EUROBAT supports the objectives of Article 8 and the development of a robust, harmonised methodology for calculating and verifying recycled content. We ask the Commission to ensure that the final methodology preserves a level playing field across battery chemistries, remains workable and proportionate for economic operators along the value chain, and reflects the operational realities of both different supply chains. EUROBAT and its members remain available to support the Commission with technical input as the methodology is finalised.
