(EU) 2023/1542 · Annex XIII(1)(c)
Battery carbon footprint in the passport: when it actually falls due
The carbon footprint is the only field in Annex XIII that requires you to calculate something rather than copy it from a document. That is why it is the most expensive one. The value is expressed in kilograms of CO₂ equivalent per kWh of total energy the battery delivers over its expected service life — which means an error in the service-life assumption shifts the entire figure.
There is no single deadline, and none of them is absolute
Article 7(1) sets four dates: 18 February 2025 for electric vehicle batteries, 18 February 2026 for rechargeable industrial batteries, 18 August 2028 for LMT batteries and 18 August 2030 for industrial batteries with external storage. Each applies “or 12, respectively 18, months after the delegated and implementing acts enter into force, whichever is the latest”. Since those acts were not confirmed as adopted when this page was written, no absolute date can be stated — and anyone quoting you one has invented it.
The declaration is more than a number
Article 7(1) requires at least seven items: administrative information about the manufacturer, information about the battery model, the geographic location of the manufacturing plant, the footprint itself, the footprint broken down by life cycle stage per point 4 of Annex II, the identification number of the EU declaration of conformity, and a web link to a public version of the supporting study. A missing link to the study is the most common reason a declaration is formally incomplete.
Why this is the hardest field for an importer
The calculation is tied to a specific manufacturing plant, not to a model. If the same model comes from two factories, you need two calculations. A supplier will often send you one generic model-level figure — that is not compliant and you cannot use it.
Where it goes wrong
- Using a generic model-level value instead of a per-plant value.
- A calculation with no link to a public version of the supporting study.
- Confusing the product footprint with a corporate emissions report — they are not the same thing.
- Assuming the deadline is 18 February 2027 because that is the passport deadline. It is not.
Frequently asked
Do I need the carbon footprint by 18 February 2027?
Not necessarily. The carbon footprint deadline is separate from the passport deadline and depends on the delegated and implementing acts. For rechargeable industrial batteries the earliest possible date is 18 February 2026, but the later of that date and 18 months after the acts enter into force applies.
Who can calculate a battery carbon footprint?
The calculation is produced by the manufacturer or an external LCA practitioner. What matters is that the method follows the implementing act under Article 7(1) and that the supporting study is publicly accessible at the stated link.
Is a carbon footprint from my cell supplier enough?
No. The footprint applies to the battery placed on the market and to the plant where it was made. A cell-level footprint is an input to your calculation, not a substitute for it.
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