Introduction
The EU Battery Regulation (2023/1542) which came into effect in February 2024, introduces stringent carbon footprint requirements starting February 18, 2025. This regulation highlights the EU's commitment to reducing environmental impact and carbon footprints throughout the battery supply chain, focusing on electric vehicle batteries, LMT batteries, and rechargeable industrial batteries with capacities greater than 2 kWh.
Carbon Footprint Requirements
The EU Battery Regulation introduces a comprehensive framework to enhance sustainability and reduce environmental impact within the battery industry. The economic operators are mandated to adhere to a series of steps, including:
Carbon Footprint Declaration
Carbon Footprint Performance Classes
Carbon Footprint Maximum Threshold
Carbon Footprint Declaration
Manufacturers must declare the carbon footprint for each battery model per manufacturing plant, which must be accompanied by technical documentation. The declared carbon footprint will be subject to conformity assessment and verified by a notified body. The declaration shall contain:
Administrative information about the manufacturer
Information about the battery model
Geographic location of the battery manufacturing plant
Carbon footprint of the battery calculated as kg of carbon dioxide equivalent per one kWh of the total energy provided by the battery over its expected service life
Carbon footprint of the battery differentiated according to the life cycle stage
Identification number of the EU declaration of conformity of the battery
Web link giving access to a public version of the carbon footprint details of the battery
Carbon Footprint Performance Classes
Batteries are classified into performance classes based on their carbon footprint, with category A representing the target, which has the least environmental impact. These classifications allow for differences among the batteries available in the market. The classes will be based on the distribution of battery carbon footprint data from declarations over the previous three years. Every three years, the Commission will evaluate the number of performance classes and the thresholds that separate them in order to reflect technological advancement and market realities.
Carbon Footprint Maximum Threshold
The maximum life cycle carbon footprint thresholds for battery categories are determined by the Commission following the completion of a specific impact assessment. Maximum thresholds refer to the highest allowable limits on the total amount of carbon emissions produced over the entire lifespan of a product, service, or process. The maximum carbon footprint criteria consider the proportional distribution of carbon footprint values of batteries in the market, progress toward carbon footprint reduction, and the EU's commitment to sustainable mobility and climate neutrality. A dedicated impact evaluation will be conducted in case the thresholds exceed the maximum threshold.
Timeline
CF - Carbon footprint
By 31 December 2030, the Commission shall assess the feasibility of extending the requirements to portable batteries and rechargeable industrial batteries with a capacity of 2 kWh or less. The EU Commission will publish delegated and implementing acts that outline specific requirements that must be met upon approval.
Methodology
The carbon footprint of batteries will be demonstrated by employing the Product Environmental Footprint (PEF) methodology. This approach is based on Life Cycle Assessment (LCA) concepts and is consistent with reputable international standards, such as ISO 14040/44 and ISO 14067. Battery carbon footprints must be calculated using the EU Commission's specified PEF method and Product Environmental Footprint Category Rules Guidance (PEFCR)
Across the entirety of the EU supply chain, all battery producers, importers, and distributors will be mandated to furnish reports on carbon footprints using the LCA approach. This ensures a consistent evaluation framework and facilitates comparisons among analogous products. Manufacturers are required to compute and denote the carbon footprint of each battery model per manufacturing plant, leveraging company- and site-specific data. To ensure transparency, the regulation necessitates the public availability of an online version of the carbon footprint details, accessible via a web link. This requirement will be integrated into the battery passport.
Functional Unit and Reference Flow
The functional unit and reference flow represent the quantified performance of a product system, used as a benchmark in an LCA study. They serve as the standard to which all carbon footprint results will be compared. The functional unit is defined as one kWh of the total energy provided by the battery system over its service life. The total energy is obtained from the number of cycles multiplied by the amount of energy delivered over each cycle. The reference flow is the weight of the battery needed to fulfil a specific function, measured in kg of battery per kWh of total energy delivered by the battery over its service life. All quantitative input and output data collected by the manufacturer to quantify the carbon footprint should be calculated in relation to the reference flow.
In some cases, the functional unit may be changed. For instance, in the case of backup batteries, the functional unit would be defined as the ability to provide one kWmin (kilowatt-minute) of backup power capability, at any moment, over the battery's lifetime. Correspondingly, the reference flow changes to kg of battery per kWmin of total energy delivered by the battery over its service life. When quantifying the carbon footprint, the battery’s exact application, such as vehicle type, must also be considered.
System Boundary
The system boundary establishes the parameters of the environmental assessment conducted for batteries in accordance with the EU Battery Regulation. It specifies the life cycle stages and processes encompassed within carbon footprint calculations, ensuring uniformity and comparability in environmental impact evaluations across the battery value chain. The use phase is expressly omitted from consideration. This concept defines the range of processes considered in an LCA study. It typically includes three approaches: Cradle-to-Gate, Cradle-to-Grave, and Cradle-to-Cradle. The EU Battery Regulation adheres to either a cradle-to-grave or a cradle-to-cradle approach, excluding the use phase.
Utilisation of Primary and Secondary Data
Battery manufacturers responsible for estimating the carbon footprint must utilise company-specific data for all battery manufacturing processes, including the production of active materials, cathodes, anodes, electrolytes, cells, housing assembly, cooling systems, modules, and batteries. This information should be tailored to the specific battery models manufactured at each production plant. For accurate carbon footprint calculations, valid and up-to-date data from the battery supply chain is essential. It is uncertain whether manufacturers consistently include primary data, rather than secondary data, in their life cycle assessments (LCAs). This limitation could result in an underestimation of the environmental impact of certain batteries.
Primary data is acquired directly from manufacturers, whereas secondary data is derived from existing databases and represents average statistics for certain processes and products. Effective coordination among all supply chain actors is critical due to the necessity for both primary and secondary data along the supply chain. Close collaboration among all participants is required to facilitate transparent data exchange, which allows accurate and representative carbon footprints to be calculated.
Environmental Performance and Impact Assessment
The verification of battery carbon footprints must follow the EC Recommendation 2021/2279 on environmental footprint methodologies for determining the life cycle environmental performance of products and organisations. Technical documentation and data-gathering tables should be provided with the assessment results. The calculated offsets shall not included in the carbon footprint declaration; however, they can be reported separately as supplementary environmental information.
The EU Battery Regulation carbon footprint requirements aim to build a sustainable and eco-friendly battery industry by bringing all stakeholders together to reduce the environmental impact of battery manufacture and use. The complexity of batteries, with their diverse supply chains and environmental implications, emphasises the importance of tailored Life Cycle Assessment (LCA) models. Delegated and implementing acts will be adopted by the Commission establishing a calculation methodology and subsequently classifying batteries into different carbon footprint performance classes. This phased approach aims to establish a maximum carbon threshold for batteries, making it a mandatory condition for their placement on the EU market.
About the Author
Junior Analyst - Battery Associates
Gokul is currently a Junior Analyst at Battery Associates. He holds a master's degree in energy engineering from Politecnico di Milano and a bachelor's degree in mechanical engineering. His expertise lies in power generation, renewable energy, and energy storage. Gokul is passionate about battery technology and its ability to fulfill the changing needs of the energy sector. He is particularly interested in battery energy storage systems (BESS) , Electric vehicles (EV) , and promoting a circular economy throughout the battery value chain.
Comments