Battery carbon-footprint declaration: what it requires and when it applies

The carbon-footprint declaration obligation under Article 7 of Regulation (EU) 2023/1542 applies to electric-vehicle batteries placed on the EU market 12 months after the Commission's carbon-footprint calculation methodology act enters into force. That puts the start of the obligation around early 2026, tracking the date the methodology and declaration-format acts take effect rather than a single fixed calendar date.

What is required

Once the obligation applies, manufacturers must provide, for each battery model and each manufacturing plant:

• Total carbon footprint in kg CO₂-equivalent per kWh of energy provided over the battery's service life.
• A breakdown by life-cycle stage (raw-material acquisition, main production, distribution, end-of-life).
• The calculation methodology set out in the Commission's delegated act for the carbon footprint of EV batteries.
• A link to a verifiable dataset in the format set by the Commission's implementing act.

What this means operationally

The declaration is a precursor to the full Battery Digital Product Passport, which applies from 18 February 2027. Data, signatures and access controls that you stand up for the carbon-footprint declaration are the same infrastructure you will extend to host the full DPP.

Foundation guidance

• Confirm the current status of the carbon-footprint methodology and format acts before assuming the declaration is in force for your products; the application date follows those acts.
• If you place EV batteries on the EU market, prepare the declaration data now so you are ready when the obligation applies.
• Start the transition to the full DPP in parallel: the data model, resolver and Verifiable Credentials infrastructure are shared.
• Track operational guidance updates via the delegated-acts tracker and the batteries sector page.