Carbon Footprint Is a Mandatory Passport Field
Article 7 of the EU Battery Regulation (2023/1542) requires every battery placed on the EU market to carry a declared carbon footprint, expressed in kg CO2 equivalent per kWh of battery capacity. This is not optional — it is a core compliance field in the battery passport, and from 2028 onwards, batteries must also carry a carbon footprint performance class label (A to E).
What the Regulation Requires
The carbon footprint declaration must cover the full lifecycle of the battery:
- Raw material acquisition and pre-processing: Mining, refining, and processing of cathode materials (lithium, cobalt, nickel, manganese), anode materials (graphite), electrolyte, and separator components.
- Manufacturing: Cell production, module assembly, and pack assembly — including energy consumption at each facility.
- Distribution: Transport of materials and finished batteries to the point of sale.
- End-of-life: Collection, recycling, and material recovery processes.
The Calculation Methodology
The European Commission has published delegated acts specifying the Product Environmental Footprint Category Rules (PEFCR) for batteries. The methodology follows ISO 14067 and the EU PEF method, requiring:
Primary data from your own manufacturing operations (energy consumption, process emissions, transport distances) and secondary data from recognised databases (such as Ecoinvent or GaBi) for upstream materials where primary data is not available.
The functional unit is 1 kWh of total battery energy storage capacity over the battery’s reference service life. This normalisation ensures comparability across different battery sizes and chemistries.
Practical Steps for Manufacturers
- Collect facility-level energy data: Electricity consumption (kWh), energy mix (renewable vs. grid), natural gas or other fuel usage for each manufacturing site.
- Request supplier carbon data: Ask material suppliers for carbon intensity data per kg of material. Where unavailable, use secondary databases with the correct geography.
- Map transport routes: Calculate emissions for material transport (sea freight, road transport, air freight) using standard emission factors per tonne-kilometre.
- Apply the PEFCR methodology: Use the prescribed allocation rules, system boundaries, and cut-off criteria. This is where most manufacturers benefit from specialised software or consultancy support.
- Third-party verification: While not mandatory in the first phase, verified carbon footprints carry significantly more credibility and may become required in later phases.
Common Pitfalls
The most common errors are using outdated emission factors, applying incorrect geographical electricity grid mixes, and double-counting recycled content credits. The regulation is specific about how recycled content is credited in the carbon calculation — it follows the Circular Footprint Formula, not simple substitution.
How Traceable Helps
Traceable’s battery passport platform includes a guided carbon footprint calculator that maps directly to the PEFCR methodology. You input your manufacturing data and supplier information, and the platform calculates the declared footprint, assigns the performance class, and includes all required documentation in the passport.