EU Battery Regulation: guide to calculating the carbon footprint

With the new EU Battery Regulation 2023/1542, a declaration on the carbon footprint of the battery is also required in the digital product passport. In this guide, we explain when the regulation applies to which batteries, which regulations are being introduced for the carbon footprint and how this is to be calculated.

Roadmap for the introduction of the carbon footprint declaration

The EU Battery Regulation was published in July 2023 and entered into force on 18 February 2024. It applies to battery cells or modules that are made available on the market for final use and are not installed or assembled in larger battery packs or batteries.

The following distinction between battery types and subtypes is defined:

• Portable batteries (batteries of 5 kg or less that do not fall into any of the other categories)
  • Subcategory: general purpose portable batteries (e.g. button cells, AAA batteries, ...)
• LMT batteries (for light means of transport, maximum 25 kg)
• Car batteries (for starters, lighting, ignition)
• Traction batteries (for the propulsion of electric vehicles)
• Industrial batteries (for industrial purposes and batteries weighing more than 5 kg that do not fall into any of the other categories)
  • Subcategory: Industrial batteries with external storage

The Battery Regulation sets (minimum) requirements for sustainability, safety, labelling and information, such as shelf life, performance, recycling content in new batteries or collection rates.

A major focus in the area of sustainability is the declaration of the carbon footprint of batteries. For each battery model in the categories of traction batteries, rechargeable industrial batteries with a capacity of more than 2 kWh and LMT batteries, a carbon footprint declaration must be prepared for each producer (production batch-specific).

This declaration must contain at least the following:

• Administrative details of the producer
• Information on the battery model
• Information on the geographical location of the battery producer's operations
• Carbon footprint of the battery, calculated as kg of carbon dioxide equivalent per kWh of total energy delivered by the battery system over its expected lifetime
• Carbon footprint of the battery, broken down by life cycle phase
• Identification number of the battery's EU Declaration of Conformity
• Web link where a public version of the study can be accessed

In addition, the carbon footprint declaration must be verified by a third party notified body.

In the next step, the European Commission will define performance classes from 2026 into which batteries will be categorised depending on their carbon footprint (similar to the energy efficiency classes for electrical appliances). Maximum values for the carbon footprint (by battery type) will then be gradually introduced.

As can be seen in the infographic below, the carbon footprint declaration for traction batteries must be available by February 2025. Industrial batteries without external storage will follow in February 2026, LMT batteries in August 2028 and industrial batteries with external storage in August 2030. The performance class must be specified no later than 18 months after the deadline for the declaration; the maximum values apply in each case 3 years after the introduction of the declaration.

Calculation of the carbon footprint

The framework conditions for calculating the carbon footprint of batteries are developed and published by the Joint Research Centre (JRC) of the European Commission. Separate calculation rules are developed for each battery type and published no later than one year before the deadline from which the carbon footprint declaration becomes mandatory.

• Definition of the functional unit: The functional unit is defined as one kilowatt hour of the total energy provided by the battery during its lifetime.
• Definition of system boundaries and data collection: The system boundaries define the processes that need to be modelled to determine the carbon footprint and those that should be excluded. They cover the entire life cycle with the exception of the utilisation phase, i.e. raw material procurement and pre-processing, battery production, distribution and end-of-life (recycling at the end of life). Specific cut-off rules are defined; in addition, all materials that together account for less than 1% of the total mass of the component may be disregarded for each system component.
• Calculation of the carbon footprint: To calculate the carbon footprint, the Climate Change impact category from the EF3.1 impact assessment method must be used. The result is given in g CO₂eq/kWh.

• Requirements for data collection: To enable broad applicability to a different number of technologies, a distinction is made between two different types of processes: mandatory company-specific and non-mandatory company-specific processes. The mandatory company-specific processes include active material and electrode production, cell production and module and battery assembly. The non-compulsory company-specific processes are further subdivided into relevant processes (firmly defined, e.g. the production of cobalt, nickel, iron and lithium) and the other, non-relevant processes. For the former, company-specific data sets may be used or developed in addition to the use of secondary data, while the use of secondary data is mandatory for non-relevant processes. This simplifies the comparability and verification of the carbon footprint.
• Modelling requirements: Contains rules for modelling specific aspects, e.g. electricity or end-of-life modelling

(Source: "Rules for the calculation of the Carbon Footprint of Electric Vehicle Batteries (CFB-EV)", Final Draft of June 2023)

Benefits of a carbon footprint

• Identifying CO₂-intensive processes and optimising them leads to significant material and energy savings and thus to cost reduction.
• Consumers and customers favour products with a low carbon footprint.
• Transparency increases trust in your company.
• Reducing your carbon footprint and transparent reporting sets you apart from your competitors and strengthens your market position.
• Sustainable business practices increasingly increase your attractiveness to investors.

Carbon footprint with EurA

Our sustainability department has extensive expertise in the sustainability assessment of battery systems thanks to its involvement in numerous research projects (ENTISE, ZiMaBat, ZinCycle, CaSino, IDcycLIB, ECO2LIB, SINTBAT). If you have any questions or are interested in working with us, please get in touch with our experts!

 Text: Levin Winzinger