Battery
The Battery Carbon Footprint Declaration (Article 7)
Battery carbon footprint declaration under Article 7: kg CO2e per kWh per model and plant, performance classes, thresholds, dates tied to the delegated act
The most debated number in the public tier of the battery passport is the carbon footprint. Yet that number is not a product of the passport but of Article 7 of the EU Battery Regulation (EU) 2023/1542: the passport merely carries the carbon footprint declaration prepared under Article 7.
Carbon footprint and the product passport sets out the general frame; here we deal only with the battery-specific rules.
What the declaration contains
Article 7 lists the content: the manufacturer's administrative details, the battery model, the geographic location of the manufacturing plant, the battery's total carbon footprint (kg CO2e/kWh), a breakdown by life-cycle stage, the identifier of the EU declaration of conformity and a web link to the public version of the study.
The functional unit deserves attention: the denominator is the total energy the battery delivers over its expected service life. A longer cycle life enlarges the denominator and lowers the unit value. Durability and carbon are therefore two ends of one calculation; the lifetime assumptions in battery state of health and dynamic data feed straight into it.
Three stages and a sliding timetable
| Stage | Content | Date mechanism |
|---|---|---|
| Carbon footprint declaration | Value and stage breakdown per model and plant | The regulation's date or 12 months after the methodology act enters into force, whichever is later |
| Performance class | Placing the value into classes defined by the Commission | 18 months after the relevant delegated act |
| Maximum threshold | Batteries above the threshold cannot be placed on the market | 18 months after the relevant delegated act |
Each stage applies first to EV batteries, then to rechargeable industrial batteries other than those with exclusively external storage, then to LMT batteries and finally to industrial batteries with external storage.
The data that feeds the calculation
The methodology follows rules drafted by the Commission's Joint Research Centre (JRC) and built on the PEF framework. The calculation covers four life-cycle stages: raw material acquisition and pre-processing, main product production, distribution, and end of life and recycling. The use stage is excluded on the grounds that it is outside the manufacturer's control; lifetime appears only in the functional unit, as the denominator.
In practice the result is usually driven by these items:
- Electricity in cell production: the plant's grid mix, and when supplier-specific electricity data is accepted, is the methodology's most critical rule.
- Cathode active material: production of nickel, cobalt, lithium and their precursor compounds.
- Anode, electrolyte and housing: graphite, aluminium and steel inputs.
- Transport: from cell to pack, from pack to market.
The plant's own electricity and material consumption must be primary data; secondary datasets may be used further upstream. See primary versus secondary data for the distinction. The declaration is not self-certified: the study is verified by an independent third party as part of conformity assessment.
How it appears in the passport
The declaration is per model and plant; the passport is per item. Each battery's passport references the declaration of the model it belongs to. The public tier shows the carbon footprint value, the performance class once applicable, and the link to the public version of the study. For the field list see battery passport Annex XIII data fields.
When the declaration is renewed (new plant data, a new methodology version) the passport is not overwritten; a new version is created and the old value stays in the audit trail.
What to do now
- Record plant-level electricity and heat consumption at meter level; keep the grid-mix documentation.
- Ask your cell supplier for cell-level carbon footprint data together with the method and boundaries used; request recycled content data in the same conversation.
- Build the product structure on a mass basis; half the calculation starts with a correct bill of materials.
- Settle who carries the duty; see battery passport: which batteries, who is responsible.
For method selection and data collection steps, see the product carbon footprint guide and how to calculate a PCF.
Frequently asked questions
When is the battery carbon footprint declaration mandatory?
For EV batteries, 12 months after the methodology delegated act enters into force; the act had not been adopted as of September 2026. Industrial and LMT batteries follow later, in sequence.
Is the carbon footprint calculated per cell or per pack?
The declaration is made for the battery model placed on the market, per plant. The cell supplier's data is an input, but the subject of the declaration is the battery itself.
Will the carbon performance class appear in the passport?
Yes, in the public tier; but the class obligation starts after the declaration. Until then the field stays empty and the passport is still compliant.
