Battery Carbon Footprint Declarations and Labels

Batteries are essential for electric vehicles and renewable energy storage, but their production can be energy-intensive. To ensure batteries contribute fully to climate goals, the EU’s new battery legislation requires manufacturers to measure and reduce the carbon footprint of battery production. In practical terms, this means companies must calculate the total greenhouse gas emissions associated with making a battery – from mining raw materials through cell manufacturing – and declare that value when selling the battery in Europe. This Carbon Footprint Declaration is a cornerstone of the Battery Regulation’s sustainability push, introducing transparency and accountability for the climate impact of batteries.

Carbon Footprint Declarations: Under Article 7 of Regulation (EU) 2023/1542, any company placing a large rechargeable battery on the EU market must complete a Product Carbon Footprint study for that battery model. Initially, this applies to electric vehicle (EV) batteries and other rechargeable batteries above 2 kWh (like large industrial batteries), with light transport batteries (LMT) following later. The carbon footprint is expressed as the total kilograms of CO₂-equivalent emissions per unit of battery capacity or energy over its expected life. Each battery model (from each manufacturing facility) will have its own calculated value. Manufacturers need to submit a formal declaration of this carbon footprint as part of the battery’s conformity assessment, and eventually this information will be made accessible (for example, via the battery’s digital passport QR code).

The implementation is phased by battery type:

• EV Batteries: All new EV batteries must have a carbon footprint declaration by 18 February 2025. This means throughout 2024, EV battery makers have been preparing life-cycle assessments in anticipation.
• Industrial Batteries (>2 kWh): These must comply by 18 February 2026, giving industrial and energy storage battery producers an extra year to perform calculations.
• LMT Batteries (e-bike, e-scooter): Carbon footprint reporting for light transport batteries is required by 18 August 2028, recognizing that these smaller batteries will be integrated later into the scheme. (Stationary energy storage batteries follow by 2030.)

Along with reporting the numeric footprint, the law introduces carbon footprint performance classes and eventually thresholds:

• From 2026, each battery’s carbon footprint will be graded into a performance class (e.g., A, B, C …) relative to benchmarks – much like an energy-efficiency label but for embodied carbon. Batteries will be required to display a label indicating their class and footprint value, making it visible to purchasers and regulators. This labeling becomes mandatory by 18 August 2026 for applicable batteries, after the EU finalizes the class definitions.
• From 2027, the Commission will set maximum carbon footprint limits. By July 2027, a delegated act will establish the highest allowable lifecycle emissions per battery type. Any batteries whose carbon footprint exceeds those thresholds will not be allowed on the EU market thereafter. This step creates a strong incentive for manufacturers to adopt cleaner processes, renewable energy, and recycled materials to keep their products within the carbon limits.

In summary, the regulation’s carbon footprint regime starts with disclosure, moves to comparative ratings, and ends with strict limits – a progressive approach to drive improvement.

How Are Carbon Footprints Calculated? (Standard Methodology)

To ensure all manufacturers calculate emissions consistently, the EU has developed a standardized methodology. The carbon footprint calculation must follow the Product Environmental Footprint (PEF) method – a life-cycle assessment approach recommended by the European Commission. The PEF method provides detailed rules on what greenhouse gas emission factors to use, how to account for materials and energy used, and how to allocate emissions across a battery’s life stages. Key points include:

• The carbon analysis is “cradle-to-grave,” covering raw material extraction, refining, component manufacturing, battery assembly, and end-of-life processing (recycling). However, the result is normalized per the battery’s expected energy throughput (kg CO₂e per kWh delivered over its lifetime) to allow fair comparison among batteries.
• Manufacturers must use Commission-approved lifecycle datasets and parameters. For example, typical use-phase assumptions (like how many times an EV battery will be charged over its life) are standardized so that one company doesn’t assume a light usage to get a better number. This creates a level playing field.
• An independent verification of the carbon footprint study is required. The carbon footprint declaration becomes part of the product’s CE compliance dossier, so a notified body will check that the company followed the methodology correctly and the numbers are substantiated. This mirrors how technical safety standards are certified, bringing the carbon footprint into the conformity assessment process.

The European Commission has issued detailed acts to codify this methodology. In April 2024, it published a Delegated Regulation on EV battery carbon footprint calculation and an Implementing Regulation on the declaration format. These outline step-by-step how companies must perform the LCA and in what template to report the results. The method builds on established standards (like ISO 14040/44 for LCA and the PEF framework) so it’s scientifically robust and familiar to industry experts. As a result, by 2025 companies large and small have a clear guide on how to compute their batteries’ footprints. Many battery makers are also using software tools and consulting services specialized in carbon accounting to assist with these complex calculations.

Status and Impact in 2025

As of 2025, the carbon footprint requirements for batteries are moving from plans to reality:

• EV Battery Declarations Begin: With the February 2025 deadline, EV battery manufacturers are now completing their first official carbon footprint declarations. This is a significant moment – it marks the first time an industry will routinely report the embodied carbon of products at point of sale. Early compliance efforts in 2024 included pilot assessments: firms calculated footprints for existing battery models to identify hot spots (like energy use in cell manufacturing or mining impacts) and took mitigation steps. By early 2025, these declarations are being submitted, and the data will soon feed into setting the performance benchmarks. The initial findings are expected to show a range of carbon intensities depending on factors such as factory energy sources (batteries made with renewable energy having lower footprints) and the supply chain of raw materials. This transparency is already encouraging better practices – for instance, some EV battery producers have signed deals to source metals from low-carbon extraction processes and to power gigafactories with green electricity, to improve their scores.
• Methodology Finalized and Ongoing Work: The Commission’s 2024 publication of the calculation rules has been welcomed as it gave industry clarity on how to comply. Technical working groups, including the European Joint Research Centre, continue to fine-tune supporting guidance (such as calculation software or default datasets for certain materials). For industrial batteries, a similar delegated act defining the carbon footprint method is expected by the end of 2024, keeping those producers on track for 2026. Stakeholders are actively engaged through consultations to ensure the rules are workable across different battery chemistries and designs. The standardized approach also means many companies are aligning their internal carbon accounting with the PEF method, creating consistency with broader corporate carbon footprint reporting.
• Looking Ahead – Labels and Limits: Work is underway in 2025 to establish the carbon footprint performance classes that will appear on battery labels from 2026. The idea is to categorize batteries (perhaps with a scale like A to G) based on their carbon emissions per kWh, enabling buyers to compare a “low-carbon” battery versus a “high-carbon” one at a glance. The Commission, likely with input from technical experts, will determine the ranges for each class (for example, Class A might be reserved for the top 10% lowest carbon batteries). These classes must be set by the time labeling becomes compulsory in August 2026. In parallel, studies in 2025 are examining what a reasonable maximum carbon threshold should be for each battery category – essentially drawing a line that by 2027–2028 no battery on the market can exceed. This might involve benchmarking current batteries and projecting improvements. By mid-2027, those thresholds will be enacted. Manufacturers are aware of this coming rule and are taking steps now to ensure future designs will meet the limits. For example, battery firms are investing in recycling facilities and cleaner production technologies to cut their carbon per battery.

The carbon footprint declaration and labeling initiative is a bold and positive experiment in industrial climate accountability. By 2025, the policy has already spurred a race to the top in clean manufacturing among battery producers. Europe’s message is clear: it’s not enough for batteries to enable electric mobility; their production must also be aligned with climate goals. If successful, this approach will reduce the overall emissions of the booming battery industry and give environmentally conscious buyers and end-users transparent information. It also sets a precedent that could extend to other products in the future. The coming years (2025–2027) will be crucial as data from these declarations shape further policy (like tightening the carbon limits). But with strong collaboration between regulators and industry, the battery carbon footprint program is on track to drive innovation and greener outcomes without compromising the growth of this key sector.

Sources Consulted:

IGARR (2024), EUR-Lex (2024), Reverse Logistics Group (2024), VATAi (2025), UL Solutions (2024)