Carbon Footprint Declarations for EU batteries

Start with category and capacity. Article 7 covers electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and LMT batteries. It does not make every portable, SLI, or small industrial battery subject to a carbon footprint declaration by default.

For rechargeable industrial batteries, keep the storage configuration visible because Article 7 uses different schedules. The declaration applies on the later of 18 February 2025 or 12 months after both required acts enter into force for electric vehicle batteries; the later of 18 February 2026 or 18 months after both acts enter into force for rechargeable industrial batteries except those with exclusively external storage; the later of 18 August 2028 or 18 months after both acts enter into force for LMT batteries; and the later of 18 August 2030 or 18 months after both acts enter into force for rechargeable industrial batteries with external storage. A missed Commission adoption deadline does not by itself activate the declaration duty.

Article 7 also excludes batteries that have undergone preparation for re-use, preparation for repurposing, repurposing, or remanufacturing if the battery had already been placed on the market or put into service before those operations.

The Article 7 declaration is made for each battery model per manufacturing plant. The minimum fields are manufacturer information, battery model information, geographic location of the manufacturing plant, lifecycle carbon footprint value, lifecycle-stage breakdown, EU declaration of conformity identification number, and a web link to a public version of the supporting study.

The Commission's draft declaration-format text turns those requirements into a table: manufacturer name or trade mark, model identifier, plant town or region and country or jurisdiction, lifecycle carbon footprint, stage-level values, the EU declaration of conformity number, and the public study link.

Batch or serial data is based on the EU declaration of conformity model, not as a standalone minimum Article 7 declaration field. If batch or serial number is needed for traceability, connect it through the EU declaration of conformity and technical file instead of adding an unsupported declaration field.

Annex II requires the calculation methodology to build on Product Environmental Footprint principles and lifecycle assessment. The standard functional unit is one kWh of total energy provided by the battery system over its service life, with special treatment for backup batteries and possible exceptions where the delegated methodology specifies another functional unit.

The declaration should show the total lifecycle carbon footprint and the Article 7 lifecycle-stage breakdown. Annex II names five stages for detailed modelling: raw material acquisition and pre-processing, production, distribution, own electricity production, and end of life.

The use phase is excluded from the lifecycle carbon footprint calculation unless choices made by the battery manufacturer at design stage make a non-negligible contribution. Offsets must not be included in the carbon footprint declaration, although they may be reported separately as additional environmental information.

The public declaration is only the visible layer. Annex VIII requires technical documentation to include, where applicable, a study supporting the Article 7 carbon footprint values and class, the calculations made under the delegated methodology, and the evidence and information determining the input data for those calculations.

The technical file should let a notified body or national authority trace the declared value back to the battery model, plant, bill of materials, energy mix, lifecycle inventory assumptions, secondary datasets, measurements, calculations, and versioned methodology used at the time of placing on the market.

For production-quality assurance, the quality system documentation must cover procedures for documenting and monitoring the parameters and data needed to calculate and update carbon footprint values and classes where Article 7 applies.

Article 7 requires a web link to a public version of the study supporting the declared values. Until the declaration becomes accessible through the QR code, the carbon footprint declaration must accompany the battery.

For batteries subject to a battery passport, Annex XIII makes Article 7 carbon footprint information public at battery-model level. The passport also makes the EU declaration of conformity public, while test reports proving compliance are reserved for notified bodies, market surveillance authorities, and the Commission.

A good public record therefore has two layers: a public declaration and study summary that users can access, and a controlled technical file that preserves calculations, supplier data, datasets, and test or audit evidence for authority or notified-body review.

Most declaration problems come from treating Article 7 as a marketing claim instead of a model-and-plant compliance record. A declaration that lacks the plant boundary, lifecycle-stage split, conformity number, or public study link is not aligned with the Article 7 minimum-information model.

Another recurring error is mixing Article 7 steps. The declaration requirement, the later performance-class label, and maximum lifecycle carbon footprint thresholds are separate obligations with separate delegated or implementing act dependencies. Keep them in distinct records until the source for each step is identified.