> EU imports basically 100% of its lithium

We don't have to. There's a large spodumene resource in Portugal.

> and cobalt

Finland alone could cover all of the European Union's need for cobalt even with zero recycling.

https://www.lyellcollection.org/doi/full/10.1144/geoenergy20...

Not that I am against recycling of lithium and cobalt -- it's just that it isn't actually needed when we could fairly easily mine both if we wanted to. Lithium recycling is commercially viable as far as I know so there's no need for the EU to legislate anything. Cobalt recycling from bigger batteries probably is, other kinds of cobalt recycling probably isn't.