EU Batteries RegulationArticle 7

EU Batteries Regulation (Regulation (EU) 2023/1542) Carbon footprint declarations

Article 7 is a staged program with plant specific declarations, performance classes, and later thresholds.

Treat the declaration as a controlled data product tied to the battery model, the manufacturing plant, and Annex VIII evidence.

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Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

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Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

Carbon footprint compliance is often reduced to a life cycle assessment report. Article 7 is stricter than that. It requires a declaration for each battery model per manufacturing plant, a public supporting study link, later performance class labels, and later maximum threshold compliance, all on dates that differ by category.

Section 1

What the declaration must contain

Article 7 requires administrative information about the manufacturer, battery model information, plant location, the life cycle carbon footprint per kWh over expected service life, the breakdown by life cycle stage, the EU declaration of conformity identification number, and a web link to a public version of the supporting study.

The declaration is plant specific. The Regulation does not allow sampling across plants producing the same battery model. That design point should shape your data model from the start.

Manufacturer and battery model details.
Manufacturing plant location.
Total carbon footprint per kWh over expected service life.
Life cycle stage breakdown.
EU declaration of conformity identifier.
Public link to the supporting study.

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Section 2

Exact application dates by category

The dates are not uniform. For EV batteries the declaration applies from 18 February 2025 or 12 months after the delegated and implementing acts enter into force, whichever is later. For rechargeable industrial batteries above 2 kWh except those with exclusively external storage, it applies from 18 February 2026 or 18 months after those acts, whichever is later. For LMT batteries it applies from 18 August 2028 or 18 months after those acts, whichever is later. For rechargeable industrial batteries with external storage, it applies from 18 August 2030 or 18 months after those acts, whichever is later.

Until the declaration becomes accessible through the QR code, it must accompany the battery.

EV declaration date: 18 February 2025 or later trigger.
Industrial above 2 kWh, except external storage: 18 February 2026 or later trigger.
LMT: 18 August 2028 or later trigger.
Industrial with external storage: 18 August 2030 or later trigger.

Section 3

Performance classes and threshold planning

Article 7 does not stop with a declaration. It later requires a label showing the carbon footprint performance class and later requires technical documentation to show that the declared life cycle carbon footprint sits below the maximum threshold for the relevant category. Those dates also differ by category.

Program teams should therefore plan three phases: declaration, performance class labeling, and threshold compliance.

Performance class label starts for EV from 18 August 2026 or later trigger.
Performance class label starts for industrial above 2 kWh except external storage from 18 August 2027 or later trigger.
Performance class label starts for LMT from 18 February 2030 or later trigger.
Maximum threshold starts for EV from 18 February 2028, for industrial above 2 kWh except external storage from 18 February 2029, for LMT from 18 August 2031, and for external storage from 18 August 2033, each subject to the delegated act timing rule.

Section 4

Governance and evidence model

The carbon footprint workflow should be controlled like regulated product data. Keep the source bill of materials, energy data, plant data, calculation assumptions, supporting study, review approvals, and publication link under version control. Also link the result to the Annex VIII technical documentation because the Regulation explicitly uses that documentation to prove compliance with Article 7.

This is especially important where the same battery model is made at multiple sites or where the plant energy mix changes materially.