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. The documentation stage covers industrial batteries above 2 kWh except those with exclusively external storage, electric vehicle batteries, and starting, lighting and ignition (SLI) batteries from the later of 18 August 2028 or 24 months after the methodology act enters into force; it reaches LMT batteries from 18 August 2033. The battery must contain cobalt, lead, lithium, or nickel in active materials. 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 record 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. From 18 August 2031, the first minimum-share step covers industrial batteries above 2 kWh except those with exclusively external storage, electric vehicle batteries, and SLI batteries: 16 percent cobalt, 85 percent lead, 6 percent lithium, and 6 percent nickel. From 18 August 2036, the later step also includes LMT batteries and sets 26 percent cobalt, 85 percent lead, 12 percent lithium, and 15 percent nickel. Do not apply the earlier minimum-share step to LMT batteries or add other materials unless an applicable delegated act changes the rule.

Annex VIII puts Articles 7 and 8 in the technical documentation as well as sustainability reporting. For Module D1, the conformity-assessment route based on quality assurance of the production process, include the carbon-footprint study, the recycled-content study, calculations under the applicable delegated-act methodology, and the evidence 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. Record the adopted methodology, verification rules and format before approving category-specific calculations or declarations. Keep unconfirmed classes, thresholds and additional material targets marked as unresolved.