Starting February 18, the mandatory product‑level carbon footprint disclosure requirements under the EU Battery Regulation (Regulation (EU) 2023/1542) officially take effect. All electric vehicle batteries and industrial batteries above 2 kWh destined for the EU market must be accompanied by a verified carbon footprint declaration; non‑compliant shipments will be denied entry into the single market. The move signals that the global battery industry has entered an era where carbon data determines market access.
Under the latest draft delegated acts published by the European Commission, carbon footprint calculations must cover the full “cradle‑to‑gate" lifecycle—from raw material extraction, cathode/anode material synthesis, and cell manufacturing to final battery assembly—using the Product Environmental Footprint (PEF) methodology as the harmonised baseline. Emissions per kilowatt‑hour of functional capacity must be clearly stated in the technical documentation, and importers are obliged to conduct due diligence on supplier data.
Thierry Breton, EU Commissioner for Internal Market, remarked at a recent industry forum: “The carbon footprint declaration is not the finish line, but the starting point of a transparent battery economy. Battery passports will be piloted from 2025, and carbon intensity thresholds will enter into force by 2027, by which time the market will have naturally phased out high‑carbon products."
According to the European Association for Storage of Energy, the industry’s most pressing challenge today is not the lack of calculation tools, but the severe shortage of primary emissions data upstream—particularly in the processing of key materials such as graphite, lithium, and nickel. Most small and medium‑sized battery enterprises have yet to establish emission factor databases directly linked to mining origins, and reliance on industry default values risks undermining the credibility of their declarations.
The China Industrial Association of Power Sources advises exporters that EU customs will begin random checks on the completeness of battery technical documentation from February 18. Missing carbon footprint declarations or incorrect formatting will directly trigger return risks. Companies are urged to initiate product lifecycle assessment (LCA) modelling immediately and secure pre‑audit slots with EU notified bodies to avoid shipment disruptions in the second quarter.