EU Batteries Regulation Carbon footprint classes FAQ

Article 7 covers electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and batteries for light means of transport (LMT). It distinguishes rechargeable industrial batteries with external storage from other rechargeable industrial batteries when setting application timing.

For those categories, the declaration and class are tied to each battery model per manufacturing plant. Teams should therefore map the battery category, model identifier, manufacturing plant, and whether the industrial battery has external storage before assigning an Article 7 workstream.

The sequence is cumulative. First, the covered battery model needs a carbon footprint declaration. Second, the battery bears a label declaring the carbon footprint performance class for that model and plant. Third, once the relevant delegated act sets maximum life-cycle carbon footprint thresholds, the technical documentation must show that the declared life-cycle carbon footprint value is below the applicable threshold.

That sequence matters because a class is not the same thing as a market-access threshold. Annex II says classes are based on the distribution of declared values for batteries placed on the market, with category A as the best class. Maximum thresholds are a later limit, set after information has been collected through declarations and class distribution and after a dedicated impact assessment.

Article 7 does not itself publish the calculation methodology, class boundaries, label formats, or maximum threshold values. It gives the Commission different tasks: delegated acts for the calculation and verification methodology, delegated acts for performance classes, implementing acts for the declaration and label formats, and delegated acts for maximum life-cycle carbon footprint thresholds.

The practical consequence is that teams should track four dependencies separately. A declaration format alone does not settle the calculation methodology, a calculation methodology alone does not set class boundaries, and a class delegated act does not necessarily mean the maximum-threshold requirement is already known.

Until the relevant class and threshold acts are available for the battery category, the useful evidence is the category and model analysis, calculation inputs, declaration fields, and change-control history. The regulation expects technical documentation to support the declared carbon footprint value and the class, including calculations and the evidence determining the input data.

Keep the evidence aligned to the model and plant. Annex II says the life-cycle carbon footprint calculation is based on the bill of materials, energy, and auxiliary materials used in a specific manufacturing plant for a specific battery model; sampling from different plants for the same model is not allowed, and a change in the bill of materials or energy mix requires recalculation.

Do not publish class boundaries, width of classes, or maximum threshold values unless the relevant delegated act for the battery category supports them. The regulation explains the factors the Commission must use, but it does not turn those factors into final numeric class boundaries in Article 7 itself.

Also avoid saying that carbon footprint classes alone determine market access. Under the Article 7 structure, the class label differentiates batteries by declared carbon footprint performance, while the later maximum life-cycle threshold is the requirement that the declared value must be below once the threshold delegated act applies.