Carbon Footprint Declaration: What the EU Battery Regulation Requires, for Which Batteries and From When

The carbon footprint rules sit in Regulation (EU) 2023/1542 concerning batteries and waste batteries (OJ L 191, 28.7.2023), in force since 17 August 2023 (Article 96(1)) and directly applicable. Article 7 belongs to Chapter II, the sustainability and safety requirements of the EU Battery Regulation.

As of 13 November 2026 the Commission had adopted none of the acts on the methodology, the declaration format, the classes or the threshold. No stage of Article 7 therefore applies yet to any battery, although three of its fixed dates have already passed.

What Does Article 7 Require on Battery Carbon Footprint?

Article 7 requires the manufacturer to calculate the carbon footprint of each battery model per manufacturing plant across its life cycle, declare it, place the battery in a performance class and, once thresholds are set, keep it below the maximum life cycle value. Article 5 makes this a condition of market access.

Article 3(1), point (21), defines the carbon footprint as the sum of greenhouse gas emissions and removals in a product system, expressed as carbon dioxide equivalents and based on a Product Environmental Footprint (PEF) study using the single impact category of climate change (consolidated text on EUR-Lex). It ranks among the EU Battery Regulation requirements.

Which Batteries Need a Carbon Footprint Declaration?

Three of the five battery categories fall under Article 7: electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh and LMT batteries. Points (a) to (d) of Article 7(1), (2) and (3) give each category its own dates.

Industrial batteries split in two. Rechargeable industrial batteries with a capacity greater than 2 kWh follow points (b), while batteries with external storage, designed to store their energy exclusively in attached external devices (Article 3(1), point (8)), follow points (d). Portable and SLI batteries are outside Article 7, as the table shows.

Table 1: Article 7 by category; the five battery categories are set in Article 1(3).

The Three Stages of Article 7

Article 7 runs in three stages for each category: a carbon footprint declaration under paragraph 1, a performance class with a label under paragraph 2, and a maximum life cycle carbon footprint threshold under paragraph 3. Article 8 applies a parallel documented and verified logic to recycled content, set out in the battery recycled content requirements.

What the Carbon Footprint Declaration Must Contain

Article 7(1) lists seven items for the declaration, from the manufacturer's administrative information to a web link to the public version of the supporting study. The seven items are listed below.

• Manufacturer's administrative information (point (a)).
• Battery model (point (b)).
• Geographic location of the manufacturing plant (point (c)).
• Carbon footprint in kg CO2e per kWh of total energy over the expected service life (point (d)).
• Carbon footprint per life cycle stage of Annex II, point 4 (point (e)).
• Identification number of the EU declaration of conformity (point (f)).
• Web link to the public version of the supporting study (point (g)).

The declared value refers to one kWh of total energy over the expected service life, never to one kWh of capacity. The declaration accompanies the battery until the information is accessible through the QR code of Article 13(6), required on every battery from 18 February 2027.

Carbon Footprint Performance Classes and the Class Label

Under Article 7(2), each battery carries a conspicuous, clearly legible and indelible label showing its carbon footprint and its carbon footprint performance class. Class A is the best class, with the lowest life cycle carbon footprint, and the classes follow the distribution of declared values over the previous three years (Annex II, point 8).

The Commission reviews the number of classes and the thresholds every three years (Article 7(2), last subparagraph). The label format sits in the Article 13(10) implementing act, not adopted as of 13 November 2026, so no class label design binds manufacturers yet, as set out under labelling and QR code.

The Maximum Life Cycle Carbon Footprint Threshold

Article 7(3) adds a maximum life cycle carbon footprint threshold that a battery must not exceed, set by delegated act. Annex II, point 9, bases the threshold on a dedicated impact assessment, the distribution of declared carbon footprint values and the contribution of the threshold to climate neutrality by 2050.

No threshold act had been adopted as of 13 November 2026, although Article 7(3) required the Commission to adopt the electric vehicle act by 18 August 2026. For every category, the fixed threshold date falls 18 months after the fixed class date, as Table 2 shows.

When Do the Carbon Footprint Obligations Apply?

Each Article 7 stage applies from a fixed date or a set number of months after the entry into force of the Commission act it depends on, whichever is the latest, so the calendar dates in Article 7 are earliest dates, not deadlines already in force.

Electric vehicle batteries come first: their declaration applies from 18 February 2025 or 12 months after the methodology and format acts enter into force, their class from 18 August 2026 or 18 months after the class and label acts, and their threshold from 18 February 2028 or 18 months after the threshold act, whichever is the latest.

The 12-month period applies only to the electric vehicle declaration; every other stage runs on 18 months. The table lists all twelve dates with the act each depends on, and every other date of the act is in the EU Battery Regulation timeline.

Table 2: The twelve application dates of Article 7(1) to (3).

Why No Carbon Footprint Stage Applies as of 13 November 2026

As of 13 November 2026 no stage of Article 7 applies to any battery, because neither the methodology delegated act nor the declaration-format implementing act has been adopted, nor have the class and threshold acts. The industrial declaration date of 18 February 2026 has passed without the duty applying.

The 12 or 18 months start only when an act enters into force. Under Article 89(6), a delegated act enters into force only if neither the European Parliament nor the Council objects within three months of notification, and the EUR-Lex record of the Regulation lists only Delegated Regulation (EU) 2025/606 as completing it.

How Annex II Sets the Carbon Footprint Calculation

Annex II sets the essential elements of the calculation: the Commission's Product Environmental Footprint method and the relevant category rules, a functional unit of one kWh of total energy provided over the service life, and four life cycle stages. Back-up batteries use one kWmin of backup power capability as their functional unit instead (point 3).

The four stages are raw material acquisition and pre-processing, main product production, distribution, and end of life and recycling (point 4).

Equipment manufacturing, assembly with OEM system components and the use phase fall outside the boundary, the use phase unless design choices contribute non-negligibly. Point 6 applies the climate change method of the 2019 JRC report "Suggestions for updating the PEF method".

Each Annex II point that governs the calculation is set out below.

What the Draft EV Carbon Footprint Methodology Proposes

The draft methodology delegated act for electric vehicle batteries (Ares(2024)3131389), open for feedback from 30 April to 28 May 2024 and not law as of 13 November 2026, proposes the EF 3.1 climate change method and the circular footprint formula for end of life.

The draft proposes full equivalent cycles per year of 60 for M1 and N1 vehicles, 20 for category L and 250 for M2, M3, N2 and N3 vehicles. It also proposes a 1 % mass cut-off per system component and a new model and declaration when CO2e rises by more than 10 %.

Carbon Footprint Delegated and Implementing Acts: Status as of 13 November 2026

As of 13 November 2026 the Commission has adopted no act under Article 7: the electric vehicle methodology delegated act and the declaration-format implementing act are drafts in inter-service consultation, and the electric vehicle class act and the industrial methodology act are at planning stage. No threshold act has been adopted either.

The Commission planned to adopt the methodology act in the third quarter of 2025 and the format act in the second quarter of 2026; both quarters passed. The drafts drew 127 and 15 feedback responses (Have Your Say 13877, 13878), and every act's status is tracked under battery regulation delegated acts.

The statutory deadlines passed too: Article 7(1) set 18 February 2024 for the electric vehicle methodology and format acts and 18 February 2025 for the industrial ones, and Article 7(2) set 18 February 2025 for the electric vehicle class act.

Each Article 7 act and its stage are set out below.

Table 4: Commission acts under Article 7. Award criteria for green public procurement of batteries depend on the class act (Article 85(3)); proposals are tracked under battery regulation amendments.

Verification of the Carbon Footprint by a Notified Body

Carbon footprint values are verified by a notified body: Article 17(2) requires Module D1 (quality assurance of the production process) for series batteries or Module G (unit verification) otherwise, applying 12 months after the Commission first publishes the list of notified bodies under Article 30(2). Article 96(2), point (b), sets that start.

The technical documentation includes the study supporting the carbon footprint values and class (Annex VIII, Part B, point 2(h)).

The notified body checks the reliability of the carbon footprint data and the proper implementation of the methodology at approval and in periodic audits (points 5.3 and 6.3), the core task of notified bodies under the Battery Regulation.

The NANDO database listed five notified bodies under Regulation (EU) 2023/1542 when checked on 12 November 2026. The manufacturer keeps the technical documentation for 10 years after placing the battery on the market (point 3). The draft methodology act proposes notified-body visits to the cell, anode, cathode and active-material plants.

Who Declares the Carbon Footprint and How It Reaches the Passport

The manufacturer carries the carbon footprint duty: Article 38(1) requires it to ensure that each battery is designed and manufactured in line with Articles 6 to 10, 12 and 14, which include Article 7, and the declaration cites the EU declaration of conformity by its identification number.

Annex XIII, point 1(c), puts the carbon footprint information of Article 7(1) and (2) in the public part of the battery passport, required from 18 February 2027 for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery (Article 77(1)) under the EU battery passport rules.

How to Meet the Carbon Footprint Requirements

Carbon footprint compliance is proven through a notified-body route, so the work starts with plant-level data per battery model long before any Article 7 date applies. The six steps below follow the order of that work.

1. Confirm which battery category applies, using Table 1.
2. Map each battery model to each manufacturing plant (Article 7(1)).
3. Collect primary data for the five components where Annex II, point 5, bars default data.
4. Prepare the supporting study for the technical documentation.
5. Plan Module D1 or G in the battery conformity assessment.
6. Record the declaration items for the battery passport data, a duty of manufacturers under the EU Battery Regulation.

A calculation made today follows Annex II and the draft methodology, because the methodology act has not been adopted. Once that act enters into force, each calculation needs a fresh check against its final text, since the draft parameters may change.

Need help with battery carbon footprint calculation and verification? The full sequence by role and category is set out under battery regulation compliance programme.

Exemptions, the 2030 Review and Proposed Changes to Article 7

Batteries prepared for re-use, prepared for repurposing, repurposed or remanufactured are exempt from Article 7(1) to (3) where they were placed on the market or put into service before (Article 7(5)). Such batteries need no new declaration, class or threshold check, as set out for second-life batteries.

By 31 December 2030 the Commission assesses extending Article 7 to portable batteries and Article 7(3) to rechargeable industrial batteries with a capacity of 2 kWh or less (Article 7(4)). Proposal COM(2025) 981 (2025/0397(COD)), pending at "Awaiting committee decision" (OEIL, as of 13 November 2026), does not amend Article 7.

Carbon Footprint Questions

Five questions recur about the carbon footprint rules of the Regulation.

Does the carbon footprint declaration already apply to EV batteries?

No: the EV declaration applies from 18 February 2025 or 12 months after the methodology delegated act and the format implementing act enter into force, whichever is the latest. Neither act had been adopted as of 13 November 2026.

Do portable batteries need a carbon footprint declaration?

No: Article 7 covers electric vehicle, LMT and rechargeable industrial batteries with a capacity greater than 2 kWh. The Commission assesses an extension to portable batteries by 31 December 2030 (Article 7(4)).

Can carbon offsets lower the declared carbon footprint?

No: Annex II, point 7, excludes offsets from the carbon footprint declaration. A manufacturer may report offsets separately, but always outside the value it declares under Article 7(1), point (d).

Is the carbon footprint declared per battery or per model?

Per model: Article 7(1) requires a declaration for each battery model per manufacturing plant, and Annex II, point 5, bars sampling across plants. The same battery model made in two plants therefore needs two declarations.

What is the carbon footprint of an electric car battery under Article 7?

The Regulation sets no fixed carbon footprint figure for an electric car battery: each manufacturer declares the value of its battery model in kg CO2e per kWh of total energy over the expected service life. Classes and the maximum threshold follow by delegated act.