The Battery Passport: Who Is Affected? Which Deadlines Apply to Calculating the Carbon Footprint?

With the new EU Battery Regulation (EU 2023/1542) , the European Union is decisively driving change in the battery industry. A central part of this regulation is the digital battery passport, which many batteries must have from February 2027.

This passport contains comprehensive information on the life cycle of a battery, from raw material sourcing to disposal and recycling.

A particularly significant new feature of the regulation is the mandatory calculation of the batteries’ carbon footprint in the battery passport.
This calculation will create transparency in the production and use of batteries and presents companies with both challenges and opportunities. For some batteries, this calculation is already mandatory from 2025, while the battery passport only has to be published in full from 2027.

Preparing for these requirements early is therefore essential.

For more information on the battery passport, download our whitepaper.

The different battery types

The EU Battery Regulation introduces specific categories of batteries to which different requirements and deadlines apply under the battery passport. Companies must know the requirements for the following battery types precisely to ensure they comply with the legal requirements:

The following battery types are distinguished, among others:

• Electric vehicle batteries:
  batteries used specifically for the traction of hybrid and electric vehicles.
• Industrial batteries:
  these batteries have a capacity of more than 2 kWh and are used in industrial applications.
• Batteries for light means of transport (LMT batteries):
  batteries used, for example, in e-bikes or e-scooters.

Gradual introduction of carbon calculation and maximum values

The carbon footprint is being introduced as a performance criterion for batteries in stages. First, calculating the emission value becomes mandatory, followed by classifying batteries into so-called performance classes. As a final step, maximum emission values are defined that batteries must comply with in order to continue to be sold on the EU market.

When introducing these measures, the EU sets different deadlines based on the different battery types.

Companies must prepare for these requirements early in order to meet the complex deadlines and calculation rules.

Stage 1: carbon footprint declaration (from 2025)

In the first stage, battery manufacturers must submit a carbon footprint declaration covering the battery’s entire carbon footprint over its life cycle. This calculation is verified by third parties and made publicly accessible via a QR code on the battery.

The carbon footprint calculation covers several life cycle phases of the battery:

Raw material acquisition and pre-processing	This includes the mining and pre-processing of raw materials and their transport.
Main product production	This step includes the production of the battery cells and the assembly of the battery.
Distribution	Transporting the finished battery to the points of sale.
End of life and recycling	This covers the collection, dismantling and recycling of the battery.

Certain phases, such as the battery’s use phase and the production of equipment for assembly or recycling, are excluded from the carbon calculation, as they either have negligible impact or cannot be directly influenced by the battery manufacturer.

Emissions are calculated in CO₂ equivalents (CO₂e) per kilowatt hour (kWh) of energy delivered and are intended to provide detailed insight into the carbon intensity of battery production.

Deadlines for the carbon footprint declaration:

From 18 February 2025	Mandatory carbon footprint declaration for electric vehicle batteries.
From 18 February 2026	Obligation also for rechargeable industrial batteries (without external storage).
From 18 August 2028	Obligation for LMT batteries (light means of transport, e.g. e-bikes and e-scooters).
From 18 August 2030	Obligation for rechargeable industrial batteries with external storage.

Stage 2: labelling in performance classes (from 2026)

From 2026, some batteries must be classified into performance classes based on their carbon intensity. This will also be made accessible via a QR code on the battery. This classification makes batteries comparable based on their CO₂ emissions, increasing pressure on manufacturers to reduce the carbon intensity of their products.

Deadlines for performance class labelling:

From 18 August 2026	Introduction of the performance class for electric vehicle batteries.
From 18 August 2027	Obligation also for rechargeable industrial batteries (without external storage).
From 18 February 2030	Obligation for LMT batteries (light means of transport, e.g. e-bikes and e-scooters).
From 18 February 2032	Introduction of the performance class for rechargeable industrial batteries with external storage.

Stage 3: introduction of maximum carbon values (from 2028)

In the final stage, maximum values for CO₂ emissions are set for certain batteries. Manufacturers must ensure that their batteries do not exceed these limits in order to continue to be sold in the EU. These maximum values are the next step in reducing emissions and are introduced in stages by battery type.

Deadlines for the introduction of maximum values:

From 18 February 2028	Introduction of maximum values for electric vehicle batteries.
From 18 February 2029	Introduction for rechargeable industrial batteries (without external storage).
From 18 August 2031	Introduction for LMT batteries (light means of transport, e.g. e-bikes and e-scooters).
From 18 August 2033	Applies to rechargeable industrial batteries with external storage.

The battery passport – what it means for companies:
act now to be prepared

The requirements for carbon footprint calculation (PCF) and compliance with maximum values present companies with major challenges. Capturing and analysing the required data requires close collaboration along the entire supply chain and the use of new technologies to provide the required carbon data in real time.

If the battery passport is missing or the carbon calculation is not submitted correctly or on time, this can lead to a complete loss of market access. EU regulations are strict, and batteries that do not provide the required data may not be placed on the market.

Companies that act now and prepare for these requirements can, however, gain considerable competitive advantages. The introduction of performance classes and maximum values in particular offers opportunities: companies that invest in low-emission production methods early and optimise the carbon footprint of their batteries will be more competitive in the long term. In addition, awareness of sustainability among consumers and investors is growing steadily, so companies that can position their products as more environmentally friendly benefit from positive market access.

Telusio’s view

Calculating the carbon footprint and the new requirements for batteries in the EU present companies with both challenges and opportunities. Those who prepare early will be able not only to meet the strict legal requirements but also to gain strategic advantages.

TELUSIO supports companies in successfully preparing for the requirements of the EU Battery Regulation. Now is the right time to act – for a sustainable future and the long-term success of your company.