The European Union (EU) has put forward a new regulatory framework for batteries through the EU Batteries Regulation (2023/1542), which sets a series of minimum thresholds of recycled materials for electric vehicle (EV) batteries sold on the EU market. Since the EU is the largest market for China’s EV export, compliance with the EU Batteries Regulation is a prerequisite for China’s EV export. To evaluate the feasibility of meeting these regulatory requirements, a future-oriented Chinese EV recycled materials use potential analysis model has been developed, forecasting the maximum proportion of recycled materials in China’s EV batteries from 2020 to 2035. To find out the risk factors, influencing aspects such as battery lifespan, demand, technology development, collection rate, and battery reshoring have been considered. The findings indicate that compared to other metals, the maximum proportion of recycled lithium is the lowest, forecast to be 21.2% in 2031, and increasing to 28.3% by 2035. Conversely, the maximum proportion of recycled graphite is the highest, at 28.9% in 2031 and reaching 41.3% in 2035. These results suggest that Chinese EV batteries could meet the targets set by the EU Batteries Regulation in most scenarios. Moreover, the analysis indicates that battery lifespan and collection rate constitute significant risk factors potentially influencing the recycled material content in Chinese EV batteries, which in turn impacts Chinese EV export to the EU. Finally, policy recommendations are proposed to enhance EV export and to bolster EV battery recycling industry development.

China has pledged to peak its CO₂ emissions by 2030 and achieve carbon neutrality by 2060. To meet these goals, China needs to accelerate the electrification of passenger vehicles. However, the rapid development of electric vehicles may impact the supply of critical raw materials, which may hinder the low-carbon transition. Therefore, the impact of vehicle electrification on CO₂ emissions and the corresponding bottlenecks in the supply of critical raw materials should be systematically considered. In this study, we developed the China Automotive Fleet CO₂ Model (CAFCM) to simulate a mixed-technology passenger vehicle fleet evolution. We further assessed the impact of energy and CO₂ emissions and evaluated the demand for critical battery materials. We designed three scenarios with different powertrain type penetration rates to depict the potential uncertainty. The results showed that (1) the CO₂ emissions of passenger vehicles in both the operation stage and the fuel cycle can peak before 2030; (2) achieving the dual carbon goals will lead to a rapid increase in the demand for critical raw materials for batteries and lead to potential supply risks, especially for cobalt, with the cumulative demand for cobalt for new energy passenger vehicles in China being 5.7 to 7.3 times larger than China’s total cobalt reserves; and (3) the potential amount of critical material recycled from retired power batteries will rapidly increase but will not be able to substantially alleviate the demand for critical materials before 2035. China’s new energy vehicle promotion policies and key resource supply risks must be systematically coordinated under the dual carbon goals.