Carbon Footprint Declaration of Batteries

The new EU Batteries Regulation 2023/1542 was published on 28th of July 2023. The Regulation sets rules on sustainability, performance, safety, collection, recycling, and second life of batteries as well as on information requirements. Among these, there is the carbon footprint of the batteries (CFB) to be determined and communicated. The CFB quantifies the total amount of greenhouse gas emissions associated with the battery throughout its entire life cycles as kg of CO2 equivalent per Functional Unit (FU).

The EU Batteries Regulation entered into force on 17th of August 2023.

Why Carbon Footprint of Batteries (CFB)?

Climate change is the second highest impact category for batteries after the mining and use of minerals and metals. Therefore, the EU aims at subsequently establishing carbon footprint performance classes that will enable batteries with lower overall carbon footprints to be identified. A crucial step towards this goal is the harmonization of the technical rules for calculating the CFB.

Based on the information collected through the carbon footprint declarations and the relative distribution of the carbon footprint performance classes of battery models placed on the market the European Commission shall set maximum life cycle carbon footprint thresholds for the battery categories that fall under the regulation.

A carbon footprint declaration shall be drawn up for each battery model per manufacturing plan.

Which batteries fall under the Battery Regulation?

The following batteries placed on the EU market are affected by the Battery Regulations:

  • Rechargeable industrial batteries with a capacity greater than 2 kWh, independent of its cell chemistry and of the specific application.
  • LMT (Light Means of Transport) batteries
  • Electric vehicle batteries

Note: Independent of the shape of the battery (prismatic, cylindrical, button, pouch cells) if they fall under the above-mentioned categories, they must have CFB.

Most relevant types of batteries to have CFB based on cell chemistry are following:

  • Lead-acid (PbA) - flooded, valve-regulated / sealed, tubular and all other forms
  • Lithium-based, including all current lithium-ion (LIB) chemistries and solid-state LIB
  • Sodium High Temperature (NaS, NaNiCl)
  • Sodium-Ion (SIB), including aqueous sodium and hybrid ion batteries (ASIB)
  • Nickel-Cadmium (NiCd), Nickel-Zinc (NiZn) and Nickel-Metall Hydride (NiMH)

Timeline for Implementation of CFB

Mandatory enforcement of the Battery Regulation began on February 18, 2024. The Figure 1 mentioned below represents the enforcement of carbon footprint declarations for different types of batteries.


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Figure 1. Timeline for mandatory carbon footprint declaration of batteries. For better view you can see the image here. 

  1. EV Batteries: CFB shall apply from the above-mentioned date or 12 months after the date of entry into force either of the delegated or the implementing act respectively.
  2. LMT and rechargeable industrial batteries with and without external storage: CFB shall apply from the above-mentioned dates respectively or 18 months after the date of entry into force either of the delegated or the implementing act respectively.

Calculation Rules for CFB

Annex II or the battery regulation lays down essential elements for the carbon footprint calculation of batteries. The methodology for calculating the carbon footprint of batteries will be defined by a delegated act of the EU and will adhere to the latest version of the commission's Product Environmental Footprint (PEF) method. Until now the European commission has published rules for the calculation of the carbon footprint of electric vehicle batteries and rechargeable industrial batteries with a capacity greater than 2 kWh.

Life Cycle Stages of Battery

Independent of the battery type the following life cycle stages shall be considered in the CFB declaration, as depicted in Figure 2.
1.pngFigure 2. Life Cycle Stages of Battery. For better view you can see the image here. 

Kiwa services in the field of carbon footprint declaration of batteries (CFB)

  • Data collection & LCA modelling of the battery products as per the guidelines.
  • Data quality rating (DQR) of the datasets.
  • Carbon footprint calculation of battery products with respect to functional unit, depending on the application of the battery.
  • Technical documentation of the carbon footprint declaration of batteries (CFB) as per EU battery regulation, accompanied by a summarized report available in both public and non-public versions to support the study.