The EU Battery Regulation (2023/1542) aims to create a comprehensive framework for the sustainable supply and value chain of batteries within the European Union. There are various key objectives introduced, among them we can mention enhancing the environmental performance of batteries, ensuring responsible recycling, achieving certain collection and recycling targets, and reducing the carbon footprint associated with batteries lifecycle.
The Battery Regulation Proposal currently includes 96 articles and 15 annexes, covering different aspects of the battery life cycle, such as sustainability, performance, safety, collection, second life application of batteries, end of life recycling, as well as information transparency (labelling and documentation, digital passport, traceability, etc).
This Regulation enforces stricter sustainability requirements than the previous directive on batteries. The Regulation, through Article 7, directly influences efforts to lower the carbon footprint of battery (CFB), encouraging the use of low-carbon materials and technologies, and supporting the transition towards a circular economy. Article 7 addresses the requirements for CFB declarations, labelling, and the maximum life cycle CFB thresholds. This blog will help you to understand Article 7 and how it applies to your product.
Please read our previous blog post, EU Battery Regulation (2023/1542) Road to Compliance, which summarises the battery types covered by the Regulation.
Article 7 specifically covers:
Portable batteries might be included after 2031 as mentioned in the regulation, ‘’By 31 December 2030, the Commission shall assess the feasibility of extending the requirements in this Article to portable batteries, and the requirement laid down in paragraph 3 to rechargeable industrial batteries with a capacity of 2 kWh or less’’.
If the product you are placing on the EU market falls within this list, you need to know that the CFB verification must be performed by a notified body in accordance with Module D1 of the Regulation.
Manufacturers must provide a CFB declaration (as a part of the technical documentation that is submitted for the declaration of conformity with the EU Battery Regulation) for each battery model per manufacturing plant. The declaration must include:
Until it becomes accessible via the QR code referred to in Article 13(6), the CFB declaration shall accompany the battery.
Each battery must have a label showing its carbon footprint and performance class based on carbon footprint data. This information should be calculated following methods established by the European Commission (through Delegated Acts) and included in the battery's technical documentation.
Ultimately, the Regulation aims to ensure that the anticipated large-scale deployment of batteries (eg 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 and the number of performance classes will be reviewed by the commission every three years to ensure alignment with market realities.
Timelines: Deadlines are set for the application of these requirements. Starting with February 2025 for electric vehicle batteries, all the way up to August 2033 for industrial batteries with external storage. The European Commission is tasked with adopting delegated and implementing acts to define the methodologies and formats that will help ensure conformity with the requirements of Article 7.
Re-use exceptions: 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 batteries which were originally sold and used on the EU market and later modified for reuse, repurpose or remanufacturing, do not need to meet the requirements of Article 7, as long as they were already compliant when first placed on the market.
The Regulation introduces a phased approach to the implementation of requirements for each type of battery (See Figure 1). Initially, the CFB declaration becomes mandatory for each type of battery. Subsequently, requirements for declaring and labelling CFB performance classes are implemented. Finally, CFB threshold requirements come into effect.
With the first major deadline for Article 7 of the EU Battery Regulation set for February 2025 (for EV batteries), a critical gap remains unaddressed, ie the methodology for calculating the CFB for EV batteries has yet to be finalised. This methodology, central to compliance, is to be established through a Delegated Act that remains in draft form and has not yet been adopted (as of 3 March 2025). Once implemented, the CFB calculation and reporting will follow the methodology defined in the Battery Regulation and its associated Delegated Act, incorporating the principles of the Product Environmental Footprint (PEF) method. The development of Delegated Acts for different types of batteries is crucial for ensuring a standardised and transparent approach to measuring and reporting their environmental impact across the EU market. These Delegated Acts represent a pivotal step in advancing sustainability in the battery industry, providing the clarity and framework needed for manufacturers to meet regulatory expectations and contribute to the EU's broader climate goals.
Although the Delegated Act for EV batteries is expected to be finalised soon, the delay has a knock-on effect on the effective date of requirements for EV batteries. For example, the effective date for CFB declaration for EV batteries will be 12 months after the Delegated Act enters into force, rather than 18th February 2025. Nevertheless, the delay presents a valuable opportunity for actors across the EV battery supply chain to start collecting data for their CFB and prepare their CFB study reports. The sooner companies begin working on their CFBs, the better. This proactive approach will make the verification of CFB studies smoother once the Delegated Act comes into force.
The primary task is to calculate the CFB for each battery type at each manufacturing plant and to prepare a corresponding CFB study report. This process requires adherence to a scientific and harmonised methodology, which will be outlined in the Delegated Act. Our next blog article will provide more detailed information about the development of CFBs, the associated Delegated Act and related guidelines.
At TÜV SÜD we offer:
I would also like to thank Leon Youngs (Head of Sustainability Services), Jonas Johannisson (Product Carbon Footprint & LCA Expert) and Daniel Philipp Müller (Carbon Footprint and LCA expert) for their contribution.
Site Selector
Global
Americas
Asia
Europe
Middle East and Africa
