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EU Battery Regulation: Carbon Footprint Calculations in Focus

Stefan Kupferschmid

Batteries are a key enabler technology in the transition to green mobility and a green energy-based economy. However, batteries are associated with various environmental impacts throughout their life cycle. To ensure a safe, circular and sustainable value chain for all batteries, the European Parliament approved a new regulatory framework in July 2023 for all batteries sold or used in the European Union.   

Mandatory sustainability requirements include carbon footprint rules, minimum recycled content guidelines, performance and battery durability criteria, as well as end-of-life management and battery disposal regulations. Most of the provisions will become binding in 2024 and, unlike EU directives, do not need to be transposed into national law. All economic operators (suppliers, manufacturers and distributors) are included in the scope of obligations under the law.  

With our advanced software solutions and extensive life cycle inventory databases, Sphera can support companies in their efforts to comply with the new EU battery sustainability requirements. Our sustainability consultants can support carbon footprint calculation and life cycle assessments (LCAs) across the entire battery value chain.  

EU Battery Regulation: Key Features  

Initially proposed by the European Commission in 2020 to replace the EC Batteries Directive from 2006, the new EU battery regulation mandates that all batteries sold or used in the EU must meet defined sustainability requirements. The key provisions include:  

  • Restrictions on the use of hazardous substances, in particular cadmium, lead and mercury.  
  • Introduction of carbon footprint rules—for example, a mandatory carbon footprint declaration by 2025, carbon footprint classes by 2026 and minimum carbon footprint thresholds by 2028.  
  • Requirements for the use of recycled content (to be phased in).  
  • Enforcement of extended producer responsibility for the collection and treatment of batteries.  
  • Establishment of a 45% collection rate for portable batteries by the end of 2023, rising to 73% by the end of 2030.  
  • Installment of battery recycling requirements—75% for lead-acid batteries, 65% for lithium-based batteries, 80% for nickel-cadmium batteries and 50% for other waste batteriesby the end of 2025.  
  • Initiation of material recovery targets—90% for cobalt, nickel, copper and lead by the end of 2027, rising to 95% in 2031; and 50% for lithium by 2027, rising to 80% in 2031.  

What Is the Scope of the EU Battery Regulation and Who Must Comply?  

The regulatory framework encompasses all categories of batteries in the EU market. Specifically, the classification covers portable batteries; industrial batteries; starting, light and ignition (SLI) batteries; electric vehicle (EV) batteries; and light means of transport (LMT) batteries, such as those for e-bikes and e-scooters.  

The EU battery regulation applies throughout the battery value chain. For example, suppliers of battery cells and modules are required to provide battery manufacturers with the necessary documentation. Products must adhere to battery safety standards, such as marking and labeling guidelines. Economic operators need to ensure that conformity assessments have been performed through certification with the CE marking 

New due diligence rules also require operators to verify the source of raw materials used for batteries. The aim is to prevent child labor and poor working conditions in the battery supply chain, in particular during commodity mining and processing.  

Mandatory Carbon Footprint Calculations for Batteries   

The new EU sustainability requirements also mandate a carbon footprint declaration by the battery manufacturers. The carbon footprint of the battery needs to be calculated and reported for each battery model, per manufacturing plant and based on site-specific primary data. The carbon footprint calculation quantifies the total amount of greenhouse gases as kilograms of carbon dioxide equivalent per one kilowatt-hour (kWh) of the total energy provided by the battery over its expected service life.  

Initially, the carbon footprint declaration requirements apply to three performance classes of battery: LMT batteries, EV batteries and rechargeable industrial batteries with a capacity above two kWh. This battery model-specific rule is anticipated to go into effect in 2024. Within the following three years, batteries will need to be labeled with their battery performance classes according to their carbon footprint declaration. By 2028 (estimated), economic operators will be required to ensure batteries comply with the maximum life cycle carbon footprint thresholds based on their declared carbon footprint.

Battery Assessment Guidelines by the Joint Research Centre   

To ensure consistency of battery assessments, the Joint Research Centre (JRC) of the European Commission is drafting rules for the calculation of the carbon footprint of electric vehicle batteries (CFB-EV). The guidelines cover methodologies, modeling approaches, documentation and verification requirements. Key takeaways of the JRC proposal are summarized below.  

Functional Unit for Battery Energy Storage : The functional unit for which the CFB is calculated is one kWh of the total energy provided by the battery system over its service life. When quantifying the carbon footprint, the battery’s exact application, such as vehicle type, must also be considered.  

System Boundaries for Battery Life Cycle Assessment : Assessment of the battery life cycle stages will cover raw material acquisition, recycled content, pre-processing, manufacturing, distribution and battery end-of-life. The use phase is explicitly excluded.  

Use of Primary Data and Secondary Life Cycle Inventory Datasets : Battery manufacturers calculating the CFB are required to use company-specific data and processes for all battery manufacturing processes, including the production of active materials, cathodes, anodes, electrolytes and cells. Company-specific data on the assembly of housing, cooling systems, modules and batteries is also required, based on the specific battery models manufactured in individual production plants.  

Environmental Performance and Verification of the CFB : Battery carbon footprint verification will have to comply with EC Recommendation 2021/2279 on environmental footprint methods to measure life cycle environmental performance. Technical documentation and data collection tables must be provided.  

Sphera’s Battery Expertise at Your Service   

With the new regulatory framework, the European Commission aims to ensure a level playing field in the EU through a common set of rules while promoting a circular economy and reducing environmental and social impacts throughout all stages of the battery life cycle.  

Sphera can help you comply with the sustainability requirements in the EU battery regulation and calculate the required carbon footprints. Our senior consultants have extensive experience in lithium-ion battery regulations for electric vehicles and other applications. They have contributed to the Product Environmental Footprint Category Rules (PEFCR) for batteries and helped create the Global Battery Alliance Greenhouse Gas (GBA GHG) Rulebook for EV batteries.   

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