How do I determine the carbon footprint of a battery?

A fixed calculation method, not a company's own calculation

The carbon footprint of a battery is not freely determined by the manufacturer or importer themselves, but according to a calculation method laid down in the Battery Regulation. Article 7 of Regulation (EU) 2023/1542 (Battery Regulation) requires that batteries within certain categories be accompanied by a carbon footprint declaration, drawn up according to a method that the European Commission develops via an implementing act. That declaration maps the greenhouse gas emissions over the lifecycle of the battery: from extraction of raw materials, via production and use, to end of life. Anyone wanting to know how that footprint is established will thus refer to a prescribed, EU-wide calculation framework, and not to a method that differs per company. The purpose of this is to make batteries comparable on the same measurement scale, regardless of who places them on the market.

Which batteries this applies to — and which it does not

Article 7 targets specific categories: batteries for electric vehicles (EV batteries), batteries for light means of transport (LMT batteries, such as e-bikes and scooters) and industrial batteries above a power rating of 2 kWh. For these categories, the requirement for a carbon footprint declaration applies, and at a later stage a classification into performance classes and possibly a maximum value that a battery must meet in order to still be allowed on the market. Batteries that fall outside these categories — such as small portable batteries for consumer electronics — are exempt from this. It is also important that the requirement comes into effect at its own time per category: not all batteries are required to have a carbon footprint declaration at the same time. Anyone wondering whether a specific battery falls within this scope should therefore first look at the category and power rating, and only then at the time when the requirement for that category comes into effect.

When exactly this comes into effect is not yet fixed everywhere

The exact dates on which the carbon footprint declaration becomes mandatory per battery category follow from the implementing acts that Article 7 requires — these dates cannot be stated in this text without consulting the current status of those implementing acts. What is clear, however, is the structure: first comes the requirement for a carbon footprint declaration, followed by the classification into performance classes, and only then possible maximum values for the lifecycle carbon footprint. For the digital battery passport itself, a different, well-established date applies: that passport is mandatory from 18 February 2027. The carbon footprint data resulting from Article 7 will, as soon as they apply, belong in that passport, but the two timelines — that of the carbon footprint requirement and that of the passport itself — do not necessarily run in parallel. For the precise scheduling of the carbon footprint requirement, the text of Article 7 and the associated implementing acts are the place to consult.

What this means in practice for those placing a battery on the market

Anyone placing an EV, LMT or industrial battery above 2 kWh on the market is well advised to first determine whether their own battery falls within one of these categories and, if so, which one. The next step is to check whether and from when a carbon footprint declaration is mandatory for that specific category — this follows from the implementing act associated with Article 7. This is then followed by the question of which data is needed to draw up that declaration: these are typically data on raw materials, production process, transport and the expected use phase, usually obtained from the manufacturer further down the chain. For those importing batteries without producing them themselves, this means in particular that these data must be requested from the manufacturer, since the declaration cannot be drawn up without the underlying figures. Finally, the carbon footprint declaration, once it applies, belongs as a data element in the digital battery passport — Annex XIII to the Regulation lists the carbon footprint as one of the data to be included in the passport. Those now preparing a passport are therefore well advised to reserve a space in the data collection for this declaration, even if the obligation for their own battery category has not yet come into force.

The legal basis: Article 7 and Annex XIII

All of this follows from Article 7 of Regulation (EU) 2023/1542 (Battery Regulation), which governs the carbon footprint declaration, the calculation method and its phased implementation, and from Annex XIII to the same Regulation, which includes the carbon footprint in the list of data that the digital battery passport must contain. For the precise scope, the calculation method itself and the current status of the implementing acts, the full text of this Regulation is the appropriate source.

Those now making preparations for the battery passport are best advised to inquire with their own manufacturer or supplier which data on raw materials and production process are available, so that this data is ready as soon as the carbon footprint declaration becomes mandatory for the battery category in question.