EV carbon footprint data

EV carbon footprint data is a declaration for each EV battery model, per production site, calculated under the methodology in the delegated act adopted under Article 7 of Regulation (EU) 2023/1542. The declaration states the carbon footprint in kilograms of CO2 equivalent per kilowatt hour of total energy provided over the battery service life, using the functional unit and system boundary in the methodology. The declaration duty for EV batteries applies from 18 February 2025 or 12 months after the delegated and implementing acts enter into force, whichever is later, subject to the current text. A carbon footprint figure without a methodology, a functional unit, and a verification statement cannot be compared with another figure, and the record must hold all three.

Carbon footprint data means the declared life cycle greenhouse gas emissions for a battery model, calculated under the Article 7 methodology. The scope is EV battery models, per manufacturing plant, for the declaration period stated.

How is the EV category decided?

EV carbon footprint data applies to that category, and the record should state the vehicle category, the weight basis, and the reason the battery falls inside the definition. Article 7 is the operative provision for the point in question, and Annex XIII sets the passport content where a passport applies. A life cycle analyst preparing a carbon footprint declaration for an EV model should not assume that a traction battery for another vehicle type follows the same entry. A declaration for a model produced at two plants should be prepared separately for each plant, with the energy mix, production data, and verification for each plant stated, rather than averaged across plants.

How are model and individual layers kept separate?

For EV carbon footprint data, the record should keep the two layers separate, with a link from the individual record to the model record. The carbon footprint study, declaration, and verification record for a model value should name the test or calculation method and the date, while evidence for an individual value should name the measurement, the date, and the source system, such as the battery management system. Carbon footprint performance classes and maximum thresholds follow later delegated and implementing acts, and class and threshold claims should be labelled expected until those acts are in force, as checked on 28 October 2026.

How are performance values stated?

For EV carbon footprint data, a capacity value, a power value, a cycle life value, or a capacity retention value should state the test conditions, the reference temperature, the charge and discharge rates, and the end point used. A life cycle analyst preparing a carbon footprint declaration for an EV model should record which requirement applies to the EV battery in question and which requirement does not, with the article reference. A declaration for a model produced at two plants should be prepared separately for each plant, with the energy mix, production data, and verification for each plant stated, rather than averaged across plants.

How is use phase information recorded?

For EV carbon footprint data, state of health, cycle count, temperature history, and fault history, where recorded, should be tied to the unique identifier and dated, so a later reader can see the sequence. The carbon footprint study, declaration, and verification record should include the data extraction date and the version of the software or method used, where that information is available. Carbon footprint performance classes and maximum thresholds follow later delegated and implementing acts, and class and threshold claims should be labelled expected until those acts are in force, as checked on 28 October 2026.

How are repair and second life operations distinguished?

For EV carbon footprint data, the record should name the operation, the operator who carried it out, the date, the parts changed, and the tests applied after the operation. A life cycle analyst preparing a carbon footprint declaration for an EV model should check whether a new passport, a linked passport, or an updated passport is required for the operation, and should record the reasoning. A declaration for a model produced at two plants should be prepared separately for each plant, with the energy mix, production data, and verification for each plant stated, rather than averaged across plants.

How is access and handover handled?

For EV carbon footprint data, the passport access rules in Article 77 set different levels for the public, for persons with a legitimate interest, and for authorities and notified bodies, and the record should not promise wider access than the Regulation allows. Carbon footprint performance classes and maximum thresholds follow later delegated and implementing acts, and class and threshold claims should be labelled expected until those acts are in force, as checked on 28 October 2026. A life cycle analyst preparing a carbon footprint declaration for an EV model should retain the handover record with the identifier, so a later dispute can be traced to a dated transfer.

How is a footprint declaration checked plant by plant?

Checking plant by plant starts with the production data for one plant: energy use, material inputs, yield, and transport, for the declaration period. The calculation is rebuilt from those inputs under the delegated methodology, and the result is compared with the declaration. A worked check for a two plant model shows two separate calculations, two energy mixes, and two declaration values, with the verifier and date for each. Averaging the two plants into one declaration fails the check, because the Regulation requires a declaration per production site. A plant that changes energy supplier mid period needs a split period calculation, with the change date recorded.

A footprint figure is a study result with a method, and a figure presented without its method is a number without a basis for comparison.