What carbon figures must not claim: comparisons, neutrality and thresholds without scope and method

A carbon footprint figure is a number with a scope, a method, a functional unit and a date. The figure on its own proves very little. The claims that are sometimes built on the figure, that one battery is better than another, that a battery is carbon neutral, that a battery meets a threshold, or that a battery is sustainable, require evidence far beyond the figure. Each of those claims has a specific failure mode, and the failure modes are worth cataloguing, because carbon figures are the most quoted and most misquoted figures in a battery passport.

The catalogue below states what a figure must never be used to claim, and what evidence the claim would require instead.

Why must a figure never be used for an unmatched comparison?

A comparison between two carbon figures is valid only where scope, method, functional unit, manufacturing plant type, electricity accounting and expected service life basis match, or where differences are stated and adjusted for in a way the method allows. A figure for an EV battery model per plant, calculated under the JRC rules, cannot be compared with a figure for a different category, calculated by a generic life cycle assessment, on a different functional unit, without a method note that explains the difference. A figure that excludes the use phase on the prescribed boundary cannot be compared with a figure that includes use, and a figure per kilowatt hour of capacity cannot be compared with a figure per kilowatt hour of total energy delivered over life. Unmatched comparison is the most common carbon error in commercial material, because numbers look comparable even when the basis differs. The remedy is to state the basis alongside every figure, and to refuse a comparison where the basis does not match.

Why must a figure never support a carbon neutral claim?

Carbon neutrality for a battery would require that the life cycle emissions, on the prescribed boundary, are balanced by removals or offsets that meet defined criteria, with the claim substantiated, verified and communicated in accordance with the applicable consumer protection rules. A carbon footprint figure alone, however low, does not prove neutrality, because the figure is a gross emissions figure, not a net figure after removals. A claim of neutrality based on offsetting is treated as an unfair commercial practice in defined circumstances under Directive (EU) 2024/825 as it applies from 27 September 2026, where the claim is based on offsetting greenhouse gas emissions and presents the product as having a neutral, reduced or positive impact. The passport record must never present a footprint figure as a neutrality claim, and must never present offsetting as if it reduced the declared footprint. Offsetting, where it is mentioned at all, must be shown separately, with the scheme, the credits and the residual emissions stated, and the record should avoid the term carbon neutral altogether unless the applicable rules are met and the substantiation is shown.

Why must a figure never claim a threshold pass before a threshold exists?

Carbon performance classes and maximum thresholds follow the declaration stage, by delegated act, with timetables by category. A figure cannot claim a class or a threshold pass before the class or threshold is established, and a figure cannot claim a pass after establishment without showing the class band or the threshold value and the comparison. A statement that a battery is low carbon, best in class, or below the threshold, without the class or threshold reference, is an unsubstantiated comparative claim. The record should show the figure, the method and the declaration, and should show the class or threshold position only where the delegated act position is settled and the comparison can be made. Where the position is expected, the record should label it expected. A future threshold is not a current pass, and a declared figure is not a class.

What does the prohibited claims table show?

What happens when a figure is quoted without its basis in commercial material?

A figure quoted without its basis in commercial material creates a claim that the underlying declaration does not support, even when the number itself is copied accurately. The commercial reader sees a number and an implied comparison or benefit, and the scope, method and date that would limit the inference are absent. The remedy is to restore the basis at the point of quotation, or to withdraw the quotation. A seller or publisher who discovers that a figure has been quoted without basis should correct the material promptly, with the corrected quotation showing the full basis, and should retain a record of the correction. Correction is more useful than deletion alone, because readers who saw the original quotation need to see what changed. The passport record itself is not responsible for commercial quotations, but the record earns trust when its figures are quoted correctly, and the record design should make correct quotation easy by keeping figure, scope, method and date together in the display.

How should a carbon figure be quoted?

A carbon figure should be quoted with its functional unit, its scope, its method reference, its plant, and its date, in one statement. A quotation that omits any of those elements is incomplete, and a quotation that adds a comparative or neutrality adjective is an overclaim. The discipline is the same as for every passport field: figure, scope, method, date, or no claim. This guide gives general educational information only and does not give legal advice for a particular battery, figure or claim.