Carbon footprint declaration explained: what Article 7 requires for a battery model

A carbon footprint declaration is a document, drawn up for a battery model per manufacturing plant, that states the carbon footprint of the model, calculated in accordance with the methodology in a delegated act and presented in the format in an implementing act. Article 7 of Regulation (EU) 2023/1542 requires the declaration for EV batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and LMT batteries. The declaration states the carbon footprint in kilograms of carbon dioxide equivalent per kilowatt hour of the total energy delivered by the battery over its expected service life, together with a breakdown by life cycle stage, the manufacturer and model identification, the manufacturing plant location, and the EU declaration of conformity reference.

The declaration must accompany the battery until the information is accessible through the QR code and the battery passport from 18 February 2027.

What is the functional unit for a battery carbon footprint?

The functional unit is one kilowatt hour of the total energy delivered by the battery over its expected service life. The functional unit matters because it decides what the figure means. A figure per kilowatt hour of total energy delivered over life is not a figure per battery, per kilogram of battery, or per kilowatt hour of capacity. Two batteries with the same capacity can have different footprints per functional unit where expected service life differs, because the total energy delivered differs. A reader who compares footprints without checking the functional unit compares figures that may not be comparable. The declaration should state the functional unit explicitly, together with the expected service life assumption and the energy delivered calculation, so that the figure can be read and, where the method allows, repeated. A declaration that states a number without a functional unit is incomplete as a record, however precise the number appears.

Which life cycle stages are covered?

The carbon footprint covers the life cycle stages that Annex II and the delegated act methodology prescribe, from raw material acquisition and pre processing, through main product production, to distribution and, as the methodology provides, end of life treatment, excluding the use phase in the sense that the methodology defines the boundary. The declaration breaks the total down by life cycle stage, so that a reader can see where emissions arise: materials, manufacturing energy, transport, and other stages as the method defines them. A breakdown that lumps all stages into one total hides the hotspots and prevents a reader from judging whether a low total reflects efficient manufacturing, low carbon energy, or an incomplete boundary. The boundary must be stated with the figure. A figure calculated on a narrower boundary must never be presented as if it covered the full boundary, and a figure that excludes a stage the method requires is not a declaration under Article 7 at all.

How do performance classes and maximum thresholds follow?

Performance classes and maximum thresholds are later stages of Article 7, following the declaration. The Commission is to establish carbon footprint performance classes by delegated act, and maximum threshold values by delegated act, each with its own timetable by battery category. A declaration states the footprint. A class places the footprint in a band relative to other models, once classes are established. A threshold sets a maximum that batteries placed on the market must not exceed, once thresholds are established. The three stages must not be collapsed: a declared footprint is not a class, a class is not a threshold pass, and a battery with a declared footprint has not necessarily met a threshold that has not yet been set. Timing for classes and thresholds is expected until the delegated acts enter into force, and the record must label timing accordingly. A passport entry that shows a class before classes are established, or that claims threshold compliance before a threshold exists, overstates the position.

What does a declaration contain in outline?

How is a declaration verified?

A declaration is verified as the delegated act and the conformity assessment procedure require, including verification of the calculation, the data, and the application of the methodology. Verification is not a general endorsement of the battery. It is a check that the declaration was calculated and presented in accordance with the prescribed method, on the data stated. The passport record should reference the declaration and, where the system provides for it, the verification position, without presenting verification as proof that the battery has a low footprint in absolute terms. A verified declaration with a high footprint is a verified high footprint. Verification proves method compliance, not environmental merit. A reader who treats verification as a sustainability judgement overreads the verification.

What limits apply to a declaration?

A declaration describes a model per plant, on a stated method, for a stated functional unit. It does not describe the single unit, a different plant, or a battery calculated by a different method. It does not prove that one battery is better than another unless scope, method and functional unit match. This guide gives general educational information only and does not give legal advice for a particular battery, declaration or transaction.