Carbon footprint declaration

What does a ‘carbon footprint declaration’ mean in practice?

The declaration must include, among other things:

  • The battery’s CO₂ footprint (kg CO₂eq per kWh) across the entire life cycle
  • Calculated using the Product Environmental Footprint (PEF) method
  • Broken down by life-cycle phase (raw materials, production, distribution, end-of-life)
  • Verified by a notified body
  • Will later form part of the digital battery passport (QR code)

The requirement for a carbon footprint declaration does not apply to all batteries – only certain categories – and the requirements are phased in gradually from 2025 to 2030 under the EU Battery Regulation (EU) 2023/1542, Article 7.

Below is an overview (for which batteries and when), formulated with a focus on practical application.

When Does the Requirement Apply?

Battery Category Deadline
EV batteries 18 February 2025
Industrial batteries >2 kWh (without external storage) 18 February 2026
LMT batteries 18 August 2028
Industrial batteries with external storage 18 August 2030

NB: The dates always apply at the latest 12 or 18 months after the relevant delegated/implementing acts enter into force – whichever comes later.

Note: Batteriretur Member Services must obtain the declaration from members – as part of the extended Producer Responsibility.