The carbon footprint declaration (CFD) is a legal requirement under the Battery Regulation (EU) 2023/1542, Article 7. It obliges manufacturers and importers to calculate and publish the total carbon footprint for each battery model per manufacturing plant, expressed in kg CO₂ equivalents per kWh of energy delivered over the battery's expected lifetime.

The requirement applies to EV batteries, industrial batteries over 2 kWh and LMT batteries. None of the deadlines have taken effect yet, because entry into application depends on when the delegated acts for the calculation methodology are adopted.

The declaration is the first stage of a three-stage process: first the declaration, then performance classes (A-G), and finally a maximum threshold, where batteries with too high a footprint can no longer be sold in the EU.

What must the declaration contain?

A carbon footprint declaration is not a free format. The Commission has adopted a standardised declaration format (an implementing act) that applies to all battery types.

As a minimum, the declaration must contain:

  • Administrative information about the manufacturer, including the name and geographical location of the manufacturing plant
  • A precise identification of the battery model
  • The total greenhouse gas emissions divided into four life cycle stages

The four stages are:

  • Raw material acquisition and pre-processing: Mining, extraction and refining of all chemical components and metals, including lithium, cobalt, nickel and graphite. The production of auxiliary materials is also included.

  • Main product production: The assembly of the battery cells and the battery system itself, including casings and battery management systems (BMS). Energy use at the manufacturing plant is a central component of this stage.

  • Distribution: Transport of the battery from the final production site to the point on the EU market where it is put into service.

  • End of life and recycling: Collection, dismantling and recycling processes. As recycling potentially displaces the need for virgin materials, the methods for allocating these benefits are described in detail in the delegated acts.

The use phase is deliberately left out. Differences in national electricity mixes and usage patterns would make it impossible to compare batteries across markets, and the purpose of the declaration is precisely comparability.

Why does the functional unit matter?

The carbon footprint is measured in kg CO₂e per 1 kWh of energy delivered over the battery's expected lifetime. It is not a simple weight-based calculation: it integrates the battery's performance and durability directly into the carbon accounting.

The total energy is calculated by multiplying the battery's usable capacity by the expected number of charge cycles. A battery with twice the lifetime, all else being equal, halves its declared carbon footprint per kWh.

The regulation thereby rewards not only lower emissions in production, but also better durability.

The PEF method and the role of the JRC

The Battery Regulation is based on the Product Environmental Footprint (PEF) method, which is the EU's common standard for calculating the environmental profile of products.

The Joint Research Centre (JRC) is the Commission's technical adviser and has translated the PEF principles into specific rules for batteries: the so-called CFB guidelines (Carbon Footprint of Batteries). The JRC has published separate methodological reports for each battery category:

  • CFB-EV: Covers batteries for electric vehicles, with a focus on lithium-ion and Ni-MH chemistries. The draft delegated act was published in April 2024, but as of March 2026 it has not yet been formally adopted.

  • CFB-IND: Covers industrial batteries without external storage over 2 kWh, including lead-acid and nickel-cadmium. The JRC report was published in April 2025 and forms the basis for the coming mandatory CFD, but the delegated act had not been adopted as of March 2026.

  • CFB-LMT: Covers batteries for light means of transport such as e-bikes and e-scooters. The draft report was published in June 2025, with a stakeholder consultation in July 2025.

For industrial batteries, the JRC methodology is particularly important, because it covers a wider range of chemistries than the EV reports and distinguishes between standard batteries (off-the-shelf) and custom-designed batteries (custom-made), a distinction that matters a great deal for how data is collected and validated.

Primary vs. secondary data

The regulation works with a hierarchy where company-specific data (primary data) has the highest priority. For certain critical components, primary data is mandatory: this applies in particular to the production of cathode materials and electronic components in the BMS, as these typically make up a significant part of the total footprint.

Secondary data (generic data from databases such as Ecoinvent or the Commission's own data packages) may only be used for less critical parts of the battery, or where primary data demonstrably cannot be obtained. This places heavy demands on supply chain management: companies must be able to document their suppliers' processes in detail to get the declaration verified by a notified body.

Electricity mix in the production stage

As a starting point, the national average electricity mix for the country of production must be used.

Manufacturers that want to claim renewable energy must document it via:

  • A direct line to a renewable energy installation, or
  • A Power Purchase Agreement (PPA) with requirements for temporal and geographical correlation and additionality

This prevents greenwashing through simple certificate purchases.

Timeline: where are we?

The implementation of Article 7 follows a phased schedule. Some dates are fixed in the regulation, while others depend on when the delegated acts are formally adopted.

EV batteries

EV batteries were intended as front-runners, but the CFD requirement had not taken effect as of March 2026. The regulation set 18 February 2025 as the initial deadline, but Article 7 contains a "whichever is later" clause: the deadline is February 2025 or 12 months after the entry into force of the delegated act, whichever is later. As the Commission did not adopt the act before its internal deadline in February 2024, the EV deadline is postponed to 12 months after adoption.

  • Performance classes (A-G) were scheduled for August 2026
  • Maximum thresholds (where batteries with too high a footprint can no longer be placed on the market) are set for February 2028

The delegated act for the calculation methodology itself had, however, not been formally adopted as of March 2026. The draft was published for consultation in April 2024.

Industrial batteries (> 2 kWh)

For industrial batteries with internal storage, 18 February 2026 is the statutory date, but the same "whichever is later" clause applies here: the deadline is the statutory date or 18 months after the delegated act is adopted, whichever is later. The act had not been adopted as of March 2026, so the requirement had not taken effect at that time. When the deadline arrives, all industrial batteries over 2 kWh placed on the EU market must be accompanied by a verified carbon footprint declaration.

  • Performance classes are expected in August 2027
  • Maximum thresholds take effect in February 2028

Industrial batteries with external storage have a considerably longer timeline: the CFD is only expected in August 2030, and the final limits in 2032.

LMT batteries

LMT batteries follow a schedule close to that of industrial batteries. As of March 2026, the first declaration formats are operational. Performance classes are expected in March 2027, and maximum thresholds in February 2030.

What has been adopted, and what is missing?

As of March 2026, the regulatory landscape is more complete than two years ago, but important elements are still missing.

Adopted:

  • The standardised CFD format is in place for all battery types, so authorities can process data consistently
  • The JRC methodological reports for EV and industrial batteries act as de facto standards
  • The framework for verification by notified bodies has been established, and the formal certification process is open

Still missing:

  • The performance classes (A-G) are being prepared: the methodology is in place, but the boundaries between the classes require benchmarking of the data now coming in through the declarations
  • The maximum thresholds for EV batteries (2028) are still being drafted
  • The delegated act for LMT batteries is in the final adoption phase

The biggest practical challenges

Implementing Article 7 is one of the most resource-intensive tasks for battery companies in recent times. Three challenges dominate:

  • Data availability in global supply chains: Collecting primary data from suppliers across continents is the biggest barrier. Many suppliers of chemicals and components are not used to reporting at the level of detail the PEF method requires. Companies report considerable difficulty in accessing sensitive information on energy use and process efficiency.

  • Calculation complexity: A PEF-compliant life cycle assessment is a complex scientific discipline. Many SMEs lack the internal expertise, and demand for LCA specialists has risen sharply as the regulation is implemented.

  • Standardisation of data formats: Several initiatives have emerged to counter chaos in data exchange. DIN DKE SPEC 99100, published in January 2025, defines exactly which data attributes the battery passport must contain and how they are formatted. The Global Battery Alliance has developed its GHG Rulebook, a set of rules aimed at harmonising greenhouse gas inventories globally.

The link to the battery passport, labelling and recycled content

The carbon footprint declaration is not an isolated requirement, but part of a coherent ecosystem in the Battery Regulation.

  • The battery passport (Article 77): Becomes mandatory from February 2027 for all EV, LMT and industrial batteries over 2 kWh. The carbon footprint is one of the most central data points in the passport and makes the climate profile available via a QR code to the whole value chain, from recyclers to end customers.

  • Labelling requirements (Article 13): The battery or its packaging must carry a visible label with the carbon footprint and, once adopted, the performance class.

  • Recycled content (Article 8): Has a direct link to the carbon footprint. From August 2028, manufacturers must document the share of recycled cobalt, lithium, nickel and lead. As secondary metals generally have a markedly lower carbon footprint than virgin materials, high recycled shares will automatically strengthen the battery's performance class under Article 7.

Summary

The carbon footprint declaration is not just a reporting exercise: it is a competitive parameter. For EV batteries, the requirement applies from 12 months after the delegated act is adopted, for industrial batteries from 18 months after. From 2028, when the maximum thresholds take effect, the carbon footprint will in practice determine which batteries can be sold in the EU.

The next steps for the companies affected are to:

  • Ensure that all active battery models have a verified declaration
  • Prioritise the shift from generic to supplier-specific data
  • Ensure that the data structures set up now are compatible with the battery passport requirements from 2027

Syntakk is built to structure and maintain product data in line with the requirements of the Battery Regulation, including carbon footprint data as part of the digital battery passport.