How Does Software Handle Carbon Footprint Data?

Software for carbon data is the system that collects activity data, applies the carbon footprint methodology, calculates the footprint for a battery model at a manufacturing site, and carries the declaration and supporting report into the passport record. Article 7 of Regulation (EU) 2023/1542 requires a carbon footprint declaration for electric vehicle batteries, LMT batteries and rechargeable industrial batteries above 2 kWh, with the methodology, performance classes and maximum thresholds set through delegated acts. Carbon software must therefore implement a methodology that is still being finalised in part, and must mark interim calculations as interim.

Carbon data work is method work before it is software work. The functional unit, system boundaries, data quality rules and calculation method determine the result, and software that calculates a footprint without implementing the method correctly will produce a precise but wrong number. The Joint Research Centre methodology work for industrial, electric vehicle and LMT batteries provides the technical support for the delegated acts, and software should be built to the JRC method and the delegated act that adopts it, with version control for each method version used.

What does the carbon footprint declaration cover?

The carbon footprint declaration covers the life cycle carbon footprint of a battery model produced at a defined manufacturing site, calculated under the harmonised rules in Annex II and the delegated act for the battery category. The declaration is specific to the model and site, sampling across sites is not allowed, and a change in bill of materials or energy mix requires recalculation. The use phase is excluded from the calculation, except where manufacturer design choices make a non negligible contribution, as set in Annex II. The result is presented in the passport and in a public report that makes the declaration transparent.

A carbon record should state the model, the site, the method version, the functional unit, the system boundaries and the recalculation trigger. A record that states only a footprint value, without model, site and method, cannot be compared or verified. A record that states the value with model, site and method allows a reviewer to judge whether the value covers the battery in hand. The declaration and the report should agree, and any difference should be treated as a record error.

How are activity data collected for carbon calculations?

Activity data for carbon calculations cover raw material acquisition and preprocessing, production, distribution, own electricity production and end of life, with company specific data required for battery specific parts such as anode, cathode, electrolyte, separator and cell casing. Activity data must refer to the specific battery model produced at the specific plant, with no default activity data for battery specific parts. Secondary datasets that are Product Environmental Footprint compliant are used in combination with company specific data, under the data quality rules in Annex II.

Worked check: a plant changes its electricity supplier, changing the energy mix for battery production. The carbon record shows a recalculation trigger, the footprint is recalculated under the same method version, and the new declaration replaces the old declaration with the change recorded. A system that retains the old footprint after the mix change misstates the footprint for batteries produced after the change. A system that recalculates without recording the trigger cannot show why the value changed.

How is the calculation method implemented in software?

The calculation method is implemented in software as a versioned calculation model, with the life cycle stages, impact assessment method, characterisation factors and data quality rules encoded as parameters, not as hard coded values. The impact assessment method is the climate change method recommended in the JRC Product Environmental Footprint work, with characterised results without normalisation and weighting, and characterisation factors from the European Platform on Life Cycle Assessment. Software should expose the method version, the parameter set and the calculation log for each declaration, so that the calculation can be reproduced.

Reproducibility should be tested by recalculating a sample declaration from the stored activity data and parameters, and comparing the result with the published declaration. A calculation that cannot be reproduced from stored data is not auditable, even when the published value looks plausible. The test should be carried out after each method version change, and the test result should be filed with the declaration evidence. A calculation model without a reproducibility test is a black box, not a compliance tool.

What is the status of carbon methodology as checked in October 2026?

As checked on 28 October 2026, the carbon footprint methodology delegated acts had not all been adopted, with JRC work published for industrial batteries in April 2025 and work progressing for LMT batteries, and the original fixed dates for declarations were conditional on the delegated act entry into force. The conditional date structure means that a declaration duty applies from the fixed date or a stated period after the delegated act enters into force, whichever is later, for the relevant category. A carbon plan that treats the fixed date alone as the duty date will be early or late depending on the act status, and the plan should track the act status per category.

A carbon status log should list, per category, the delegated act, its status, the fixed date, the conditional period and the resulting expected application date, labelled expected. A log that lists only the fixed date misstates the duty where the act has slipped. A log with the act status and the conditional calculation allows planning to be updated when the act is adopted, without rebuilding the whole timetable. The log should be dated as checked on 28 October 2026, with a review trigger for the next act publication.

How are performance classes and thresholds handled?

Performance classes and maximum threshold values for carbon footprint are set through delegated acts following the declaration duty, with classes applying a stated period after the declaration duty and thresholds applying later still. Software should therefore separate the declaration calculation from the class assignment and the threshold check, with each step gated on the relevant delegated act. A system that assigns a class before the class delegated act is adopted will assign a class on an assumed scale, and a system that checks a threshold before the threshold act is adopted will check against an assumed limit.

Class and threshold handling should be implemented as configurable rules, with the rule version, the act reference and the application date recorded per battery model. A configurable rule that is changed without a version record cannot be audited, and a hard coded class scale cannot be updated when the act changes the scale. The configuration record is part of the declaration evidence, and it should be reviewed when the relevant act is adopted.

What verification applies to carbon data?

Carbon footprint declarations must be verified by a notified body where the Regulation requires third party verification for the carbon footprint and recycled content requirements, under the conformity assessment procedures in Article 17. Verification covers the calculation, the activity data, the method application and the declaration presentation. Software should support verification by providing the calculation log, the activity data, the method version and the declaration in a form that a verifier can test, without granting the verifier update rights over the passport fields. As checked on 28 October 2026, verification planning should be tied to the delegated act timetable for the category. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Carbon software should make the calculation reproducible, and the method version should travel with every declaration.