The European Union Battery Regulation (EUBR) establishes a comprehensive framework designed to build a sustainable battery supply chain across Europe. It sets objectives and targets for responsible recycling and collection, as well as life cycle performance requirements.
Article 7 of the EU Battery Regulation covers rechargeable industrial batteries with capacities above 2 kWh, as well as electric vehicle (EV) and light means of transport (LMT) batteries. It aims to lower the carbon footprint of batteries (CFB) through low-carbon materials and technologies, while supporting the transition towards a circular economy. It also addresses the requirements for CFB declarations, labelling, performance classes and maximum life cycle CFB thresholds. Verification by a notified body will be required as part of the applicable conformity assessment route, once the relevant delegated act and conformity assessment conditions apply.
To ensure consistency and regulatory compliance, verification by a notified body must follow explicit assessment procedures. Under Annex VIII of the EUBR, conformity verification must be executed using either Module D1 (quality assurance of the production process) or Module G (verification based on unit verification). Identifying which assessment path applies early on will help manufacturers streamline their audit readiness with notified bodies.
Manufacturers must provide a CFB declaration for each battery model per manufacturing plant. This declaration forms part of the technical documentation submitted with the Declaration of Conformity (DoC). The declaration must include:
Until the declaration is made available through the QR code, in accordance with the EUBR, manufacturers should ensure that the declaration is provided in the form required by Article 7 and Article 13.
Once the relevant requirements apply, batteries in scope will have to display carbon footprint information and, at a later stage, the applicable carbon footprint performance class. This information should be calculated following methods established by the European Commission and included in the battery's technical documentation.
The EUBR aims to ensure that the anticipated large-scale deployment of batteries (e.g. in transportation applications) is associated with the lowest possible carbon emissions. Therefore, by specified dates, batteries must meet certain CFB limits. The maximum life cycle CFB thresholds will be introduced through associated delegated acts. Delegated acts are used when legislative acts need to be regularly updated to take into account technical and scientific progress. The Regulation also foresees that performance classes and maximum thresholds may be updated through delegated acts to reflect technical and scientific progress.
Under the EU Battery Regulation (2023/1542), mandatory carbon footprint declarations are required for:
A battery’s carbon footprint is calculated by dividing total lifecycle greenhouse gas emissions by the total energy the battery delivers over its entire service life.
The standard formula to calculate a battery's carbon footprint is:
Functional unit: The result is expressed in kilograms of CO2 equivalent per 1 kilowatt-hour (kg CO2e/kWh) of total energy provided across the battery's lifetime. For back-up batteries, the functional unit is kilowatt-minutes (kWmin) of backup power capability.
Batteries that have been repurposed, remanufactured or reused are exempt from these requirements, if they were placed on the market before undergoing such operations. This means that they do not need to meet Article 7 requirements, if they were compliant when first placed on the market.
Rather than imposing all obligations simultaneously, the EUBR enforces compliance through a clear, three-stage progression for each battery category:
While current Article 7 requirements focus heavily on electric vehicles (EVs) and larger industrial storage, the regulatory scope will expand in the coming years. By 31 December 2030, the European Commission is committed to assessing the feasibility of extending carbon footprint requirements to cover portable batteries, alongside rechargeable industrial batteries with capacities of 2 kWh or less.
The implementation roadmap spans nearly a decade to allow the battery supply chain adequate time to adapt. While electric vehicle requirements lead the initial rollout, the complete phased enforcement extends all the way to August 2033, when final maximum carbon footprint threshold limits come into full effect for industrial batteries with external storage.
Mandatory CFB calculations and study reports must incorporate the principles of the Product Environmental Footprint (PEF) method. Structuring early data-collection efforts around PEF principles ensures that lifecycle assessments remain standardised, accurate and ready for verification once delegated acts enter into force.
While Article 7 originally envisaged the introduction of carbon footprint requirements from February 2025 onwards, the calculation and verification methodology for EV batteries has not yet been finalised. As the carbon footprint declaration requirements are linked to the adoption and entry into force of the relevant delegated act, the applicable date has effectively been postponed.
Given the continued delay in the adoption process and ongoing policy discussions regarding the final methodology, manufacturers should not expect carbon footprint declaration requirements for EV batteries to become applicable before 2027 at the earliest. Nevertheless, organisations should continue monitoring regulatory developments and maintain their preparation activities to ensure readiness once the delegated act enters into force.
The current delay should not be viewed as a reason to postpone preparations. Instead, manufacturers can use this additional time to establish robust and scalable compliance processes. While carbon footprint calculations and study reports will ultimately be required for individual battery models and manufacturing sites, the greater challenge for most organisations lies in creating efficient processes for data collection, supplier engagement, calculation methodologies and technical documentation across wider product portfolios. Manufacturers that implement harmonised and repeatable approaches across multiple battery models early on will be significantly better positioned once battery carbon footprint declaration requirements become applicable and verification activities commence.
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