In July 2017, the European Commission announced plans to adopt a new legislative proposal. This proposal establishes a uniform format for businesses to declare the Carbon Footprint of their batteries (CFB), marking a significant step in the EU’s commitment to reducing the environmental impact of batteries.

On 12 July 2023, the EU adopted Regulation (EU) 2023/1542 concerning batteries and waste batteries. This Regulation aims to reshape the entire battery value chain, from raw material extraction to end-of-life recycling. The Regulation addresses three interconnected challenges related to batteries: the lack of a harmonised regulatory framework for circular and sustainable battery production, an inefficient recycling market, and the failure to achieve fully closed material loops. It also tackles social and environmental risks beyond the scope of the EU’s pre-existing environmental and sustainability legislation.

Following the latest regulatory sustainability models outlined in the European Commission’s Circular Economy Action Plan (CEAP), the Regulation introduces thirteen key measures to address these challenges. Among these, manufacturers of electric vehicle batteries (EV), rechargeable industrial batteries with a capacity exceeding 2 kWh (IND), and light means of transport battery (LMT) batteries are required to declare the CFB for each battery model and manufacturing plant.

The CFB declaration obligation will take effect no earlier than 18 February 2025 (EV), 2026 (IND), 2028 (LMT), and 2030 (IND-ES).

According to the harmonised format, each battery model’s CFB must, as a minimum, include the following information:

• Information about the battery manufacturer (company name, registered trade name, or registered trademark)
• Information about the battery model (unique identifier)
• Geographic location of the specific manufacturing plant (including town, region, country, or jurisdiction)
• Life-cycle CF in kg CO₂-eq. per kWh, as well as lifecycle stage-specific CF details (including raw material acquisition and pre-processing, main product production, distribution, and end-of-life recycling)
• EU Declaration of Conformity identification number
• Public web link to the carbon footprint study

Impact on Businesses:

To ensure compliance within the established deadlines, businesses involved in the battery supply chain should undertake the following steps:

• Knowledge: familiarise themselves with the specific compliance needs.
• Documentation: collect and calculate CF data for each battery model and manufacturing site.
• Tools: implement documentation and reporting systems.
• Labelling: ensure appropriate and compliant battery labelling.
• Audit: conduct internal and third-party audits to verify compliance.
• Training: train staff on compliance requirements and processes.
• Stakeholder Engagement: engage in dialogue with suppliers, customers, and regulatory bodies.
• Monitor and Update: continuously update compliance efforts based on regulatory changes and prepare for upcoming performance class and CF threshold requirements.

By staying proactive and informed, businesses can navigate the updated regulatory landscape and ensure compliance with the extended deadlines. For more details, check the official Commission proposal here.

Contact person: Bobby Arash