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.


What is the EU Battery Regulation?

Batteries are a key element for sustainable power supply, green mobility and the reduction of greenhouse gas emissions. Under the European Green Deal, the EU Battery Regulation 2023/1542 was therefore introduced to make the entire life cycle of batteries more sustainable. It includes stricter regulations on the production, use and disposal of batteries. The regulation aims to minimise the environmental impact of batteries, promote the circular economy and reduce dependence on critical raw materials by improving the collection, reuse and recycling of batteries. A particular focus is on the reduction of hazardous substances and the promotion of transparency and traceability through the digital product passport.

What is a digital product passport?

It is an electronic document that contains important information about a product throughout its life cycle, from manufacture to disposal. In the case of batteries, the digital product passport provides details about their composition, performance, recyclability and carbon footprint in the form of a printed or engraved QR code. This enables consumers, manufacturers and authorities to obtain transparency about the ecological and economic value of the product.



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.

In principle, the rules are based on the components of a life cycle assessment or the Environmental Footprint (EF) method (Commission Recommendation (EU) 2021/2279).
  • 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.
There are also requirements for data collection and modelling:
  • 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
Once the carbon footprint has been calculated, verification by a notified body is required. Two reports must be prepared for this: In the public version, the result of the carbon footprint and some selected key values are disclosed for transparency and comparability. The non-public version is more comprehensive and contains all modelling assumptions with justifications and detailed data collection tables. This version is confidential and only accessible to the notified body as part of the verification process.

(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

In addition to fulfilling the regulatory obligation, determining the carbon footprint of products such as batteries has many other advantages:
  • 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.

Particularly with regard to the planned maximum values, you should start determining the carbon footprint at an early stage in order to implement possible reduction measures in good time!



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

Levin Winzinger

Your contact person
Levin Winzinger

Do you want to learn more about this topic? Schedule a meeting with an expert.

Thank you for reading! The world of sustainability, life cycle assessment and carbon footprints is fascinating and I invite you to dive deeper with me. As an M.Sc. Chemical Engineering, sustainability is not only my professional expertise but also my passion, and I look forward to sharing this enthusiasm with you. If you want to learn more about the challenges and opportunities in this field, contact me and let's develop your projects together for a greener and sustainable world.

Max-Eyth-Straße 2
73479 Ellwangen

T- 079619256-0