Carbon footprint declaration

## Carbon footprint declaration A carbon footprint declaration is a formal statement of a product's life-cycle greenhouse gas emissions, expressed in kilograms of carbon dioxide equivalent and calculated under a prescribed methodology. In EU law it is becoming a mandatory market access document: the Batteries Regulation phases in compulsory declarations for EV, industrial and LMT batteries, followed by performance classes and maximum thresholds. ### Key facts - A carbon footprint declaration reports greenhouse gas emissions across the product life cycle, usually in kg CO2e per kWh of battery capacity or per declared unit. - Regulation (EU) 2023/1542 introduces mandatory declarations for EV batteries, rechargeable industrial batteries above 2 kWh, and light means of transport batteries, with phased application dates. - The methodology is fixed by Commission delegated acts based on the Product Environmental Footprint (PEF) method, so manufacturers cannot choose their own calculation approach. - Declarations must be included in the battery's technical documentation and, from 18 February 2027, accessible through the battery digital product passport via a QR code. - Later phases add carbon footprint performance classes (labelling bands) and then maximum life-cycle carbon thresholds that batteries must not exceed to be placed on the market. - Verification by a notified body is required for the carbon footprint declaration under the Batteries Regulation, making it a third-party attested claim. - The Ecodesign for Sustainable Products Regulation extends the same logic beyond batteries: future delegated acts can require carbon or environmental footprint declarations for other product groups. ### What a carbon footprint declaration is A carbon footprint declaration translates a product's climate impact into a single comparable number. The calculation follows life-cycle assessment principles: raw material extraction and processing, manufacturing energy, transport, and in some methodologies end-of-life treatment are inventoried, converted to carbon dioxide equivalents using standard emission factors, and summed. The result is declared per functional unit, for batteries per kilowatt-hour of total energy, so that a large and a small battery can be compared on intensity rather than absolute emissions. The regulatory innovation is not the concept but the standardisation. Voluntary carbon footprints have existed for years, but their results were not comparable because companies chose different system boundaries, allocation rules and data sources. The EU approach fixes the methodology in law: delegated acts under the Batteries Regulation specify the PEF-based calculation rules, the required primary data, and the format of the declaration. A declaration that does not follow the prescribed method is not a valid declaration, regardless of how carefully it was computed. The declaration is distinct from carbon offsetting or "carbon neutral" claims. It does not say the emissions were compensated; it says what they were. That makes it an information instrument first and a performance instrument second: the early phase requires disclosure, and only later phases impose maximum thresholds that can block market access. ### Why it matters for market access The carbon footprint declaration is one of the first EU product requirements to make climate performance a condition of market access rather than a marketing choice. In the disclosure phase, a battery without a valid declaration cannot be placed on the EU market, because the declaration is part of the conformity documentation. In the threshold phase, a battery whose footprint exceeds the maximum cannot be placed on the market at all, however well it performs on safety or durability. This reorders sourcing decisions. Because the methodology counts upstream emissions, the carbon intensity of the electricity used in refining and cell manufacturing dominates many battery footprints. Two chemically identical cells can have very different declared footprints depending on where and how they were made. Procurement teams must therefore evaluate suppliers on carbon data quality and grid intensity, not only on price and technical specification, and contracts need clauses requiring suppliers to provide primary activity data for the calculation. The notified-body verification requirement adds a further gate. The declaration must be checked by an independent conformity assessment body, which means the underlying data, models and assumptions must be audit-ready. Companies that treat carbon accounting as a spreadsheet exercise will fail verification; companies that build it into their quality and supplier management systems will pass. For non-EU manufacturers, this is a new competence to build or buy, and it sits alongside the existing CE marking and safety testing workload. ### Who it applies to The mandatory regime centres on batteries under Regulation (EU) 2023/1542: - Manufacturers of electric vehicle batteries placed on the EU market, who must draw up the declaration for each battery model per manufacturing plant. - Manufacturers of rechargeable industrial batteries with a capacity above 2 kWh, a category that includes energy storage systems. - Manufacturers of light means of transport batteries, such as those for e-bikes and e-scooters, in the later phase of the timetable. - Importers and authorised representatives of those batteries, who must ensure the declaration exists and is available before placing products on the market. - Upstream suppliers of cells, active materials and refined metals, who are not directly obliged but must supply the primary data their customers need. Beyond batteries, the Ecodesign for Sustainable Products Regulation empowers the Commission to require environmental footprint information, including carbon declarations, for any product group covered by a future ecodesign delegated act. Textiles, electronics, steel and other priority groups identified in the ESPR working plan are candidates. Any manufacturer of physical products sold in the EU should therefore treat battery rules as a preview of broader obligations. ### Requirements and process Producing a compliant carbon footprint declaration involves five steps. 1. Determine applicability and timing. Identify the battery category and the model-and-plant granularity the regulation requires. The declaration is per battery model per manufacturing plant, because the plant's energy mix is part of the calculation. Check the phase-in date for the category: obligations apply from different dates for EV, industrial and LMT batteries. 2. Collect life-cycle data. Map the supply chain for the materials and energy flows the delegated act requires. The methodology distinguishes company-specific primary data, which must be used where available for the manufacturer's own processes, from secondary datasets for upstream background processes. Supplier engagement is the critical path: refiners and cell producers must provide activity data in the prescribed format. 3. Calculate using the prescribed method. Apply the PEF-based rules in the delegated act: system boundaries, allocation between co-products, electricity modelling rules, and the treatment of recycled content. The delegated acts also define which life-cycle stages are included and how the result is rounded and expressed. Using a generic LCA tool with default settings will not produce a compliant result unless it implements the delegated act's rules. 4. Obtain notified-body verification. A notified body designated under the Batteries Regulation verifies the declaration. The verification covers the data, the calculation and the correct application of the methodology. The verified declaration then forms part of the technical documentation supporting the battery's conformity assessment. 5. Publish and maintain. The declaration must be made available through the battery passport from 18 February 2027, and it must be updated when the underlying data changes materially, for example when production moves to a new plant or the energy supply changes. Performance classes add a labelling obligation: the battery's carbon class must be shown, allowing buyers to compare at a glance. Later phases layer on maximum thresholds. Once a threshold applies to a category, exceeding it means the battery cannot be placed on the EU market, turning the declaration from a disclosure duty into a product ban mechanism for high-carbon production. ### Market access relevance The declaration requirement changes the economics of battery supply chains serving Europe. Manufacturing location is now a compliance variable: production powered by low-carbon electricity yields a lower declared footprint and, once thresholds apply, a wider margin of market access. Investment decisions for gigafactories already factor in grid carbon intensity alongside labour and logistics costs. For importers and distributors, the declaration is a document check at the border of the compliance process. Before placing batteries on the market, they must verify that the declaration exists, that it covers the correct model and plant, and that it has been verified. Accepting a supplier's marketing-style "carbon report" instead of the regulatory declaration is a compliance failure. Brands should also prepare for buyer behaviour. The performance class label will let fleet operators, automakers and consumers compare batteries on carbon at the point of purchase, and public procurement rules increasingly reward lower-carbon products. A strong declared footprint becomes a commercial advantage; a weak one becomes a visible liability. Early investment in primary data collection pays twice: once in compliance, once in competitiveness. ### Common misconceptions | Misconception | Reality | |---|---| | "A voluntary carbon footprint report satisfies the requirement." | Only a declaration calculated under the delegated act's methodology and verified by a notified body counts. Marketing reports do not. | | "Offsets can reduce our declared footprint." | The declaration reports life-cycle emissions as calculated. Offsetting is a separate claim governed by separate rules and does not change the declared number. | | "Only the finished battery manufacturer is affected." | The finished manufacturer declares, but the calculation depends on primary data from material and cell suppliers, who must provide it. | | "Thresholds apply immediately." | The regime is phased: declaration first, then performance classes, then maximum thresholds. Each phase has its own application date by battery category. | | "One declaration covers all our plants." | The declaration is per model per manufacturing plant, because plant-level energy data drives the result. | | "This only matters for batteries." | Batteries are first. The ESPR framework can impose footprint declarations on other product groups through delegated acts. | ### Frequently asked questions Which batteries need a carbon footprint declaration? Under Regulation (EU) 2023/1542, electric vehicle batteries, rechargeable industrial batteries with capacity above 2 kWh, and light means of transport batteries, each on its own phased timetable. Portable batteries of ordinary household types are not currently in scope for the declaration. Who verifies the declaration? A notified body designated under the Batteries Regulation. Self-declaration is not sufficient; independent verification of the data and calculation is a legal requirement. What happens if our footprint exceeds the future maximum threshold? Once a maximum threshold applies to the battery category, batteries above it cannot be placed on the EU market. The remedy is to reduce the footprint, typically by changing energy sourcing or suppliers, and to re-verify. How does recycled content affect the declaration? The delegated methodology includes specific rules for modelling recycled content, generally giving credit for the avoided burden of primary production. Accurate recycled content data, with chain-of-custody evidence, therefore improves the declared result. Do we need to redo the declaration for every shipment? No. The declaration is per battery model per manufacturing plant and remains valid while the underlying production conditions are representative. Material changes in energy supply, suppliers or processes require an update and re-verification. Where will customers see the declaration? From 18 February 2027 it is accessible through the battery digital product passport via the QR code on the battery. Performance classes will additionally appear as a label, enabling direct comparison between models. ### Sources - Regulation (EU) 2023/1542 on batteries and waste batteries (EUR-Lex): https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng - European Commission, batteries policy page: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en - Regulation (EU) 2024/1781, Ecodesign for Sustainable Products (EUR-Lex): https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng