Carbon footprint and recycled content evidence for EU battery models

For Article 7, the carbon-footprint track applies to electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and light means of transport (LMT) batteries. The evidence file should identify the battery model, the manufacturing plant, the battery category, and whether any external-storage distinction matters for the industrial-battery cohort.

For Article 8, the recycled-content track is different: it covers industrial batteries with a capacity greater than 2 kWh, electric vehicle batteries, SLI batteries, and LMT batteries where the article applies, but only when the battery contains cobalt, lead, lithium, or nickel in the relevant active materials or battery content. Do not apply Article 7 and Article 8 as one combined checklist.

The Article 7 declaration is made for each battery model per manufacturing plant. The file should preserve the manufacturer administrative details, model details, manufacturing-plant location, total carbon footprint, life-cycle-stage breakdown, EU declaration of conformity identification number, and the public link to the supporting carbon-footprint study.

Carbon-footprint classes and maximum life-cycle carbon-footprint thresholds should only be filled when the relevant delegated or implementing act and format are available for the battery category. Until then, keep a controlled status value such as 'awaiting applicable delegated act' rather than inventing a class boundary or threshold.

Article 8 starts as documentation about recovered-material shares before it becomes a minimum-share technical-documentation requirement. The documentation should show the percentage share of cobalt, lithium, and nickel in active materials recovered from battery manufacturing waste or post-consumer waste, and the percentage share of lead present in the battery recovered from waste.

The minimum-share rows should be kept separately from the disclosure rows. For the grounded Article 8 thresholds, the file can record 16 percent cobalt, 85 percent lead, 6 percent lithium, and 6 percent nickel for the earlier minimum-share step, and 26 percent cobalt, 85 percent lead, 12 percent lithium, and 15 percent nickel for the later step. Do not add other materials unless a delegated act adds them.

Annex VIII makes Articles 7 and 8 a technical-documentation problem, not just a sustainability-reporting problem. For Module D1, the technical documentation should include the carbon-footprint study, the recycled-content study, the calculations made under the applicable delegated-act methodology, and the evidence and information determining the input data.

The quality system should document how the manufacturer monitors the parameters and data needed to calculate and update recycled-content shares and, where applicable, carbon-footprint values and classes. A notified body can check the reliability of that data and the implementation of the calculation methodology.

Supplier evidence should be collected at the same granularity as the legal evidence: battery model, manufacturing plant, material stream, year, and calculation version. A generic supplier sustainability letter is weak support if it cannot be traced to the cobalt, lead, lithium, nickel, or carbon-footprint input used in the calculation.

For carbon footprint, supplier data should connect upstream materials, manufacturing inputs, plant allocation, and life-cycle-stage values to the Article 7 study. For recycled content, supplier data should connect recovered material to battery manufacturing waste or post-consumer waste, then to the Article 8 percentage calculation.

The evidence file should distinguish binding Batteries Regulation text, adopted delegated acts, draft or technical-support material, and internal assumptions. Article 7 expressly depends on delegated and implementing acts for calculation methodology, declaration format, performance classes, label formats, and maximum life-cycle carbon-footprint thresholds.

Article 8 also depends on a delegated act for the calculation and verification methodology and documentation format for recovered-content shares. Until the relevant source is available in the evidence set, the page should not state ungrounded class thresholds, category-specific formats, or extra recovered-material targets.