The Battery Carbon Footprint Declaration: What Importers Need to Collect

Among the fields a battery passport carries is a carbon footprint declaration. For importers, this is one of the parts of the data set that depends most on the manufacturer, so it pays to understand what it is and how to collect it well ahead of the deadline. This guide explains the essentials.

What the carbon footprint declaration is

The EU Battery Regulation requires certain batteries to have a carbon footprint declaration: a statement of the battery's carbon footprint prepared to a defined method, covering the emissions associated with the battery across the life-cycle stages the regulation specifies. It is not a marketing figure. It is a declared value produced to a set method, which is what makes it comparable across products.

The declaration feeds into the passport as one of the Annex XIII data groups. See Annex XIII explained.

Why it is mostly your supplier's data

The carbon footprint depends on how and where the battery and its materials were made: the electricity used in cell production, the origin of the materials, the manufacturing processes. That information sits with the manufacturer, not the importer. As the operator placing the battery on the market you are responsible for the declaration appearing in the passport, but you will be collecting the underlying figures from your supplier rather than calculating them yourself.

This is exactly why the passport belongs in your purchasing conversation. A supplier that can produce a proper carbon footprint declaration is easier to work with than one you have to chase after the order. See what your supplier must send you.

What to ask your supplier for

When you request carbon footprint data, ask for enough to stand behind the declared value:

• The declared carbon footprint figure for the specific model, to the regulation's method.
• The basis of the calculation: which life-cycle stages and which method were used.
• The supporting documentation that evidences the figure, so it is not a bare number.

The carbon footprint rules sit in Art. 7 of Regulation (EU) 2023/1542 and apply to electric vehicle batteries, rechargeable industrial batteries over 2 kWh, and LMT batteries. The declared value is expressed in kilograms of CO2 equivalent per kWh of energy the battery delivers over its service life, calculated to a life-cycle method whose detail the Commission sets in a delegated act following the essential elements in Annex II. The obligations phase in per category and in steps: first the declaration, then a performance class, then a maximum threshold. Each start date is the later of a fixed calendar date or a set period after the underlying acts are in force, so the effective date moves if those acts are delayed. Electric vehicle and industrial batteries come first; for LMT batteries the declaration does not begin before 18 August 2028. For most LMT importers the immediate task is therefore to confirm your supplier can produce the figure, not to publish one tomorrow.

How it fits the timeline

Carbon footprint obligations under the regulation are phased and category-dependent, so the first practical step is to confirm what applies to the batteries you import and when. Because the data originates upstream and can take time to produce, treat it as a long-lead item: request it early, and do not assume every supplier already has it ready.

In short

The carbon footprint declaration is a defined, method-based statement of a battery's carbon footprint that the passport carries as part of the Annex XIII data. The underlying data comes from your manufacturer, so request the figure, its calculation basis and the supporting documentation early. Confirm which categories and dates apply to your products, since the requirements are phased.