Recycled Content
Recycled content is the proportion of recycled material in a product, expressed as a percentage by weight. Under ESPR, minimum recycled content requirements are set in delegated acts for specific product categories, and recycled content percentage is a mandatory DPP data field.
Full Definition
Recycled content is defined in ESPR Article 2(20) as "the share of recycled material in a product or its packaging, expressed as a percentage by weight." ESPR sets minimum recycled content requirements for specific product categories through delegated acts. For batteries, the Battery Regulation sets minimum recycled content requirements for cobalt (16% from 2031, 26% from 2036), lithium (6% from 2031, 12% from 2036), nickel (6% from 2031), and lead (85% from 2031).
Recycled content claims must be verified — manufacturers cannot simply declare a recycled content percentage without evidence. The EU Commission is developing a methodology for recycled content verification that will be referenced in ESPR delegated acts. In the interim, manufacturers should use ISO 14021 (Environmental labels and declarations — Self-declared environmental claims) as the basis for recycled content claims.
Recycled content is one of the most commercially sensitive data fields in the DPP because it directly affects product competitiveness. Products with higher recycled content have a lower carbon footprint (recycled materials typically have lower embodied carbon than primary materials) and may command a price premium in the EU market. Conversely, products that fail to meet minimum recycled content requirements cannot be placed on the EU market after the applicable mandatory date.
Related Terms
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →Recycled Content Calculation Methodology
The recycled content of a product is the proportion of the product's mass that consists of recycled material. The calculation methodology for recycled content under ESPR will be specified in the delegated act for each product category. The EU Commission is developing a harmonised recycled content calculation methodology based on the ISO 14021 standard (Environmental labels and declarations — self-declared environmental claims) and the Ellen MacArthur Foundation's Material Circularity Indicator. The key distinction in recycled content calculation is between pre-consumer recycled content (manufacturing waste that is recycled back into the production process) and post-consumer recycled content (material that has been used by consumers and then recycled). ESPR is expected to prioritise post-consumer recycled content, as it has a greater environmental benefit than pre-consumer recycled content.
Recycled Content Verification
The ESPR delegated acts will specify verification requirements for recycled content claims. For high-value materials such as recycled cobalt, lithium, and nickel in batteries, third-party verification by an accredited auditor will be required. For lower-value materials such as recycled plastic in packaging, self-declaration with supporting documentation from material suppliers may be sufficient. Manufacturers should obtain recycled content certificates from their material suppliers and retain these certificates as part of their technical documentation. Industry certification schemes such as the Global Recycled Standard (GRS) and the Recycled Claim Standard (RCS) provide a framework for verifying recycled content claims that is likely to be recognised under ESPR.
Recycled content claims in ESPR DPPs must be supported by third-party verification. The verification process involves auditing the manufacturer's supply chain to confirm that the claimed recycled content is accurate — specifically, that the recycled materials were sourced from post-consumer or post-industrial waste streams, that the recycled content percentage was calculated using an approved methodology (such as the ISO 14021 mass balance method), and that the recycled content claim is consistent with the product's bill of materials. Manufacturers that use the Recycled Claim Standard (RCS) or the Global Recycled Standard (GRS) for their recycled content claims will have a foundation for ESPR DPP recycled content verification, as these standards require third-party certification of recycled content claims.