A breakdown of the battery carbon footprint CFF

Context of the Circular Footprint Formula

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With the entry into force of the Batteries Regulation (EU) 2023/1542, the carbon footprint of batteries is becoming a central criterion for access to the European market. Manufacturers must now quantify, declare and, in time, comply with greenhouse gas emission thresholds across the entire life cycle of batteries. In this context, the consideration of circularity — and in particular the recycling of critical raw materials and strategic materials such as nickel, cobalt or lithium — becomes a major methodological challenge. How should environmental impacts be allocated across multiple life cycles? How to avoid both double counting and the absence of incentives for recycling ? With the Circular Footprint Formula (CFF).

Indeed, it is to address these questions that this formula was introduced as part of the work of the European Commission, notably through the Product Environmental Footprint (PEF) method. The CFF provides a harmonised approach to modelling flows of recycled materials and recovered energy, allocating impacts between the upstream and downstream life‑cycle stages using parameters. Unlike traditional approaches such as cut‑off or avoided burden, the CFF aims to strike a balance by sharing the impacts and benefits of recycling between the different product systems.

The European carbon footprint methodology requires the use of a specific battery CFF. In this article, we aim to break down this formula and explain how manufacturers and LCA practitioners can prepare for its implementation.

It should be emphasised that the carbon footprint calculation methodology applied to batteries is not not yet finalised and calculation rules, including the CFF, are likely to evolve in future regulatory versions. This article and the «Carbon Footprint» article will be updated when the final version of the delegated act is released.

A breakdown of the CFF battery

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A 6-part CFF formula…

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The CFF for batteries introduced in the draft delegated act (DDA) is divided into six parties, each with its own settings:

Each part of the CFF must be applied directly to the relevant flows, as illustrated in the diagram below. For production waste (scraps), there is no dedicated formula; it depends on the real end‑of‑life treatment of the waste (incineration, recycling, etc.).

… with 3 main distinctions

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This segmentation takes into account three distinctions in the application of the CFF:

the EoL of properly collected and non-properly collected waste batteries

the waste collection rate and recycling rate

impact allocation factors (A) for raw materials, batteries at EoL, PWB at EoL, and plastics at EoL

These distinctions directly influence how emissions are attributed, particularly in cases where collection efficiencies and material recovery rates diverge. As a result, the CFF becomes sensitive to end‑of‑life operational performance. In practice, however, a default inventory for cell recycling and a collection‑rate parameter of 80% are imposed by the regulation, and primary data may only be used under specific conditions.

Moreover, the use of different allocation factors at the materials, cells, and electronic components levels introduces flexibility in how impacts and credits are distributed between the two life cycles, thus allowing the specifics of each value chain to be reflected. However, in practice, these allocation factors, denoted by A, are uniformly set to 0.2 by default in the DDA.

What are the practical implications of the battery CFF ?

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How to prepare for the battery CFF?

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Given the level of methodological complexity and the granularity of data required, as well as the limited implementation timeframe following the publication of the final Delegated Act, waiting for the definitive regulatory texts or the compliance deadlines could significantly increase both costs and risks.

The most effective approach is to anticipate early. This section therefore sets out best practices to be ready to calculate the regulatory battery carbon footprint when the time comes.

1. Integration of end-of-life processes and secondary materials into LCA models

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Indeed, a first step consists of extend existing LCA models, focused today on manufacturing, in order to take into account end-of-life processes and secondary material flows.

This includes:

The modelling of disassembly steps and other pre-processing steps such as the preparation of the black mass.

The integration of black mass refining processes inventories of the DDA or, where possible, primary inventories.

The integration of recycled materials flows in the active materials and battery casing manufacturing stages.

2. Parameterisation of LCA for robust, flexible, and modular LCA modelling

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In order to anticipate changes in battery end‑of‑life management, in the production process or in the regulatory text, it is recommended to implement a robust parameterisation of the LCA model. This allows the model to be used as a decision‑support tool both for regulatory compliance and for internal decision‑making.

This can take the form of parameterising the:

CFF parameters, both fixed (factor A) and variable (collection rate, proportion of recycled materials, etc.)

main recycling processes according to the Black Mass composition and recycling yields.

approaches by-product allocation economic based on market price and mass-based on yields.

Parametric modelling approaches offer a additional flexibility to explore scenarios going beyond regulatory compliance. Parameterised recycling models allow for the evaluation of different technologies, black mass compositions and recycling yields, thereby supporting R&D and process optimisation. In parallel, parameterised co-product allocation allows for efficient model updates in response to vMarket price variations or to methodological choices, without requiring model reconstruction.

Our support for the battery CFF application and end-of-life modelling

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Our expertise in the overall functioning of battery EoL processes and in the CFF enables us to support you in your preparation for the battery CFF and carbon footprint.