The European Union is continuing to implement the Batteries Regulation (EU) 2023/1542. These regulations require the declaration of the carbon footprint of Electric Vehicle (EV) batteries, these include rechargeable batteries, Light Means of Transport (LMT) and industrial rechargeable batteries with a storage capacity of over 2kWh.
One key step is particularly awaited by stakeholders in the sector: the publication of the delegated act specifying the official methodology for calculating and verifying the carbon footprint of EV batteries. This act will form the basis of the methodologies for the two other types of batteries carbon footprint calculation.
Released in April 2024, a draft version provides an initial overview of the expected methodological requirements. To anticipate future regulatory requirements today, here is our breakdown of the main calculation guidelines of the draft delegated act.
Why a delegated act on the carbon footprint of EV batteries?
This act sets out the rules for data collection, the modelling of processes throughout the life cycle, and the verification process for environmental declarations. To date, several methods coexisted to calculate the carbon impact of a battery, making it difficult to compare batteries.
Delegated act now imposes a unique European methodology for calculating the carbon footprint of EV batteries, based on : unique on a European scale, based on:
Clear objectives
Comparability
Provide users with an interoperable and reliable carbon footprint that is comparable between all battery models sold in Europe
Transparency
Publish the carbon footprint for all stages of the lifecycle to make it more transparent, findable and accessible and encourage improvement
Reduction
Prepare for the implementation of performance classes and a maximum threshold to respect for batteries covered by the carbon footprint declaration
Which stages of the life cycle should be included in the carbon footprint of batteries?
A cradle-to-grave analysis
Assessing the carbon footprint of EV batteries includes :
Operations annex to direct production (e.g. infrastructure, administration, R&D) are excluded from the calculation of the carbon footprint.
A defined and standardised functional unit
The final result must be expressed in kg CO₂e/kWh, based on the energy delivered by the battery over its lifetime. The definition of the latter is in discussion and will be defined in the finalised version of the delegated act.
What does the regulation require in terms of data selection and quality?
The choice of background data to be used for the calculation is also specified and is divided into two main categories, mandatory primary data and secondary data. The quality of the data used is a selection criterion and must be disclosed.
Mandatory company-specific processes
The manufacturers must provide specific primary data averaged over 1 year (exceptions apply) for all manufacturing processes of battery main components (i.e. active materials, cathode, anode, cells, modules, pack, electronic components and thermal control systems). This data includes:
- The supplier provides the full list of inputs and outputs of its process to the manufacturer.
- The supplier carries out internally an aggregated LCA data and provides it to the manufacturer.
- The supplier calls on an external consultant to conduct an LCA and provide aggregated data to the manufacturer.
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Strictly regulated generic data
For secondary data, the delegated act proposes 2 categories of upstream processes: non-mandatory most relevant processes (possible primary data), and other processes. To chose secondary data, the act requires the use of European EF3.1 datasets («ILCD entry-level compliant», EF4.0 to come), if adequately representative. Otherwise, other secondary EF-compliant data of sufficient quality can be used.
How is data quality assessed?
Each dataset, whether specific or generic, is associated with a Data Quality Rating (DQR) based on its technological, geographical, and timerepresentativeness. DQR requirements differ depending on whether the data used is primary or secondary. The DQR is also used to select secondary datasets.
The final carbon footprint must also display its own DQR, obtained by weighting the DQRs of all the underlying processes modelled.
How is electricity modelled according to the delegated act?
The current version of the delegated act requires the use of the national mix of the activity's location. However, it also allows the declaration of directly connected« electricity» (e.g. solar panels) with conditions of proof.
Nevertheless, this choice remains a talking point and could change in the final version of the delegated
act. This is one of the factors affecting the delay in publication of the delegated act.
How are co-products, recycling and circularity managed?
Allocation rules for co-products
When several products are produced by the same process, the methodology for allocating impacts is ranked in a clear order:
1. Subdivision,
2. Physical allocation,
3. Economic allocation, under certain conditions.
Modelling recycling and secondary materials
The delegated act defines two generic life cycle inventories (LCI) to be used by default to determine the impact of end-of-life recycling by pyrometallurgy or hydrometallurgy.
Primary data could be used if, and only if, they are supported by contractual agreements with a recycler.
Regulation (EU)2023/1542 imposes recycling efficiency rates and incorporation rates of recycled metals.
The used recycled materials can be modelled by other generic LCIs, in line with EF methodology.
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Taking circularity into account: allocation using the Circular Footprint Formula (CFF)
The delegated act mandates the use of the CFF to include recycled content, promote materials recycling at end-of-life, and avoid double counting of benefits.
The text defines the default values of the CFF parameters, thereby setting standardised assumptions on recovery rates of certain materials.
Read all about the CFF batterie in our next article!
How is the carbon footprint calculation verified?
Mandatory verification by a notified body
Before being placed on the market, each manufacturer must have the carbon footprint checked by a third-party organisation : this concerns the complete calculation model, the data used and the methodology.
The notified bodies will be appointed by the EU member states according to criteria defined by the regulation.
The public version of the study
A summarized version of the calculation report of the carbon footprint of batteries must be made public, in addition to displaying the results (in kg CO₂e/kWh) on the battery.
Regulatory carbon footprint in a nutshell
What does this mean for you?
Conclusion
By imposing a common method, the EU is aiming to set a clear, thorough but essential framework to compare, improve and manage the environmental performance of batteries.
Manufacturers must now structure their data, strengthen collaboration with their suppliers and anticipate future obligations. Anticipating the regulation on battery carbon footprint declaration is therefore essential for stakeholders in the European industry.
In the long term, this increased transparency will contribute to a better design of more sustainable batteries, and will accompany the transition to carbon neutrality by 2050.