FOCUS Sustainability


CALCULATING THE CARBON FOOTPRINT OF BATTERIES


Grant Gibbs, Senior Manager for Energy Storage at TÜV SÜD, discusses the requirements of carbon footprint declarations within the EU Batteries Regulation


O


n 18 August 2025, the new EU Batteries Regulation (2023/1542) replaced the previous Batteries Directive. In contrast to a


directive, a regulation is a legal act which applies automatically and uniformly in all EU countries, without the need for transposition into national law. UK-based operators who place or put into service batteries and battery- powered products must also comply. The regulation covers the entire life cycle of a battery and introduces new categories of batteries according to their use and design. New provisions for calculating the carbon footprint of batteries and setting recycled content targets for various elements have also been introduced (cobalt, lead, lithium, nickel). Article 7 of the Regulation covers


rechargeable industrial batteries with capacities above 2kWh, as well as electric vehicle (EV) and light means of transport (LMT) batteries. It aims to lower the carbon footprint of batteries (CFB) through low-carbon materials and technologies, while supporting the transition towards a circular economy. It also addresses the requirements for CFB declarations, labelling, performance classes and maximum life cycle CFB thresholds. The extension of these requirements, to include rechargeable industrial batteries with a capacity of 2kWh or less, is expected by 31 December 2030. Meanwhile, any product that falls within this   Manufacturers must provide a CFB declaration as a part of the technical documentation, which is submitted as part of the Declaration of Conformity (DoC) for each battery model per manufacturing plant. The declaration must include: • Administrative information about the manufacturer.


• The battery model.


• The battery manufacturing plant’s location.  • A weblink to the public version of the CFB


study.


• The carbon footprint per kilowatt-hour (kWh) of total energy provided over the


30 September 2025 | Automation


CALCULATING THE CARBON FOOTPRINT OF BATTERIES


battery’s life cycle, broken down by life cycle stages.


Each battery must have a label showing its carbon footprint and performance class. This information should be calculated following methods established by the European Commission and included in the battery’s technical documentation. Ultimately, the Regulation aims to ensure that the anticipated large-scale deployment of batteries (e.g. in transportation applications) is associated with the lowest possible carbon  batteries must meet certain CFB limits. The maximum life cycle CFB thresholds will be introduced through associated delegated acts. Delegated acts are used when legislative acts, like the EU Batteries Regulation, need to be regularly updated to take into  example, the thresholds and the number of performance classes will be reviewed every three years, to ensure alignment with market realities.


Batteries that have been repurposed,


remanufactured, or reused are exempt from these requirements, if they were placed on the market before undergoing such operations. This means that batteries that  remanufactured do not need to meet Article 7 requirements, if they were compliant when  Timeline: The Regulation introduces a phased approach to the implementation of requirements:


• Electric vehicle (EV) batteries - from 18 February 2025 or 12 months after the entry


into force of the delegated/implementing act. • Industrial rechargeable batteries with a capacity greater than 2 kWh - from 18 February 2026 or 18 months after the delegated/implementing act. • LMT batteries - from 18 August 2028 or 18 months after the delegated/implementing act.


• Rechargeable industrial batteries with external storage (with a capacity greater than 2 kWh) from 18 August 2030 or 18 months after the delegated/implementing act.  was February 2025, the methodology for calculating the CFB for EV batteries had not  central to compliance and must be established through a delegated act, the adoption of it was delayed. This delay has a knock-on  for EV batteries will be 12 months after the Delegated Act enters into force, rather than 18th February 2025. However, such delays in the future present an opportunity for the battery supply chain to start collecting data for their CFB and prepare their CFB study reports. The primary task is to calculate the CFB for each battery type at each manufacturing plant, and to prepare a corresponding CFB study report. The sooner companies begin working on their CFBs, the better. This proactive approach will make the  relevant delegated act comes into force.


TÜV SÜD www.tuvsud.com/en-us/services/testing/ battery


automationmagazine.co.uk


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