Carbon and recycled content fields: where footprint and recycled shares sit in a passport

Carbon footprint information and recycled content information sit in the public model summary in Annex XIII point 1, as declarations for a battery model. Carbon footprint declarations are required by Article 7 for EV batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and LMT batteries. Recycled content documentation is required by Article 8 for industrial batteries, EV batteries, SLI batteries and, on a later timetable, LMT batteries, for the materials cobalt, lead, lithium and nickel recovered from waste and present in active materials.

Both duties are model level duties, drawn up per battery model and per manufacturing plant for carbon footprint, and both depend on delegated and implementing acts for method and format. Timing for both must therefore be labelled expected until the delegated act position is settled for the category in question.

Where does carbon footprint information sit?

Carbon footprint information sits at model level, in the public tier, with the declaration reference, the manufacturing plant, the carbon footprint value in kilograms of carbon dioxide equivalent per kilowatt hour of total energy delivered over expected service life, the breakdown by life cycle stage, and the performance class where a class has been assigned. The value is a declaration for the model and plant, calculated by the method in the delegated act and verified as that act requires. It is not a measurement of the single unit, and it is not a value for a different plant. A passport entry that shows a carbon figure without the plant, the scope and the declaration reference is partly present. A passport entry that shows a carbon figure for a model without stating whether the declaration duty has applied for that category is incomplete as a record, because the reader cannot tell whether the figure is a required declaration, a voluntary statement, or a placeholder.

Where does recycled content information sit?

Recycled content information sits at model level, in the public tier, as the share of cobalt, lead, lithium and nickel recovered from waste and present in active materials, for the battery model. The share is calculated by the method in the delegated act under Article 8, and the documentation accompanies the battery until the information is accessible through the passport. The entry must state the material, the share, the basis of calculation, and the date or version of the documentation. A share for one material must never be presented as a share for the battery as a whole, and a share calculated by one method must never be compared with a share calculated by another without a method note. Minimum recycled content percentages apply from 18 August 2031 and higher percentages from 18 August 2036 for the categories in Article 8, subject to amendment by delegated act. Those minimums are thresholds for the future, not descriptions of current batteries, and the record must keep the threshold and the declared share apart.

How is timing shown for both fields?

Timing is shown by stating three things for each duty: the category, the date in the Regulation, and the delegated act condition. Article 7 dates apply from the stated calendar date or, if later, 12 or 18 months after the relevant delegated or implementing act enters into force, depending on the paragraph. Article 8 documentation duties apply from 18 August 2028 or 24 months after the delegated act, whichever is later, for the categories then in scope, and from 18 August 2033 for LMT batteries. As checked on 28 October 2026, the methodology delegated act position for EV batteries had not settled into a fixed application date in the sources consulted for this guide, and the record must therefore label carbon and recycled content timing as expected where the act position is unsettled. A fixed date must never be asserted for a duty whose application depends on an act that has not entered into force.

What does the placement table show?

How are the two fields kept from contaminating each other?

Carbon and recycled content are different claims with different methods, different scopes and different evidence. A low carbon figure does not prove high recycled content. A high recycled share does not prove a low carbon figure. The record keeps the two fields in separate entries, each with its own scope, method and declaration reference, and never merges them into a single sustainability score. A reader who sees both fields together should read them as two independent declarations, not as two halves of one claim. The evidence trace for each field is separate: the carbon trace leads to the carbon declaration and the method act, and the recycled content trace leads to the recycled content documentation and the calculation method. Merging the traces produces a record that appears stronger than either declaration alone.

What limits apply to reading these fields?

A carbon figure does not prove that a battery has a lower impact than another battery unless scope, method, plant and functional unit match. A recycled share does not prove that a battery is recycled, sustainable or circular in general terms. Both figures are declarations for a model, and both require the underlying declaration and method to be inspected before a comparative or purchasing decision is made. This guide gives general educational information only and does not give legal advice for a particular battery, declaration or transaction.