Article 7 of the EU Battery Regulation regulates the battery carbon footprint in three stages: declare, classify, cap. The first base dates have passed - and the duty still does not apply, because every deadline is tied to a legal act that does not yet exist. This guide explains the mechanism, works the calculation through on an example, and says what is worth preparing now.
The EU Battery Regulation does not treat the carbon footprint as a single duty but as an escalation across three stages. Anyone who only knows the first underestimates what follows.
Article 7 of Regulation (EU) 2023/1542 applies to electric vehicle batteries, rechargeable industrial batteries above 2 kWh and batteries for light means of transport. Stage one requires a carbon footprint declaration per battery model and per manufacturing plant. Stage two adds a label that assigns the battery to a performance class. Stage three turns the footprint into a market-access condition: batteries above a maximum threshold may no longer be placed on the market. A reporting duty becomes a limit value, step by step.
Calculate the value, have it verified and ship it with the battery.
The battery additionally carries a label showing its class.
Batteries above the threshold may no longer be placed on the market.
Annex XIII point 1(c) requires the battery passport to carry "the carbon footprint declaration referred to in Article 7". The passport content is therefore derived: if the underlying Chapter II duty falls away, there is nothing to declare. The same logic governs recycled content, which comes from Article 8 - see Battery recycling & recycled content.
The base dates from Article 7 appear in every overview, usually as deadlines. They are not: each date competes with a second one, and the later of the two governs.
Article 7(1) states the start of application twice over: for electric vehicle batteries 18 February 2025 or twelve months after the entry into force of the delegated or the implementing act; for rechargeable industrial batteries above 2 kWh 18 February 2026 or 18 months after that - in each case "whichever is the later". Both acts are still not in force. The second track therefore has no date at all, the maximum of the two is open, and the duty has simply not begun.
As at 4 September 2026
Many overviews write "from 18 February 2025 every electric vehicle battery needs a carbon footprint declaration". That is half the rule. Planning on it means buying advisory and verification work for a deadline that is not running - and, conversely, risking the loss of the real twelve or eighteen months of lead time once the act does arrive.
You do not have to interpret the legal position to know it: the Commission described it in its own battery passport material during 2026.
In its webinar on the digital product passport for batteries on 7 July 2026, Directorate-General GROW groups carbon footprint, recycled content and due diligence together as "not yet applicable", and records for the footprint that no indication of timing is possible at present - once adopted, more than a year would remain to comply. Three weeks later, on 28 July 2026, the guidance document with the 71 numbered data points of the battery passport appeared; since 15 August 2026 it applies in version 2.0. There, point #17 carbon footprint declaration and point #18 carbon footprint label carry no mandatory marking for any of the three categories; instead they are flagged as not to be filled in or displayed as of February 2027, because the format is still to be specified in the upcoming implementing act.
| Data point | Source | Status on 18 Feb 2027 |
|---|---|---|
| #17 Carbon footprint declaration | Annex XIII point 1(c) | Not to be filled - format pending |
| #18 Carbon footprint label | Annex XIII point 1(c) | Not to be displayed - classes missing |
| #20-23 Recycled content Co, Li, Ni, Pb | Annex XIII point 1(e) | Not to be filled - follows Article 8 and the delegated act |
| #24 Share of renewable content | Annex XIII point 1(f) | Mandatory |
The recycled-content row changed between the two editions: the first version of 28 July 2026 still listed recycled content as mandatory, while version 2.0 of 15 August 2026 puts it on the same footing as the carbon figure. The four values are not to be filled on the deadline and follow Article 8, whose documentation duty starts on 18 August 2028. Which fields actually have to be populated on 18 February 2027 is set out in What data goes into the battery passport.
A battery's carbon footprint is not a number but a quotient. And the denominator is not the one most data sheets use.
Article 7(1)(d) requires the value as kilograms of CO2 equivalent per kilowatt-hour of the total energy the battery provides over its service life. Studies, press releases and supplier declarations almost always quote the footprint per kilowatt-hour of capacity instead. Both numbers describe the same battery, but they differ by the factor of the assumed full cycles - at a service life of 1,500 cycles, by more than three orders of magnitude. Adopting the wrong one does not produce a rounding error; it produces an unusable figure.
Assumptions: 60 kWh usable capacity, 1500 full cycles of service life, hence 90000 kWh of energy delivered.
Both numbers describe the same battery. They differ by exactly a factor of 1500 - the number of full cycles assumed as the service life in this example.
The breakdown by life-cycle stage is not optional decoration but item (e) of the declaration. Annex II point 4 draws the system boundary and names the stages that belong inside it: raw material acquisition and pre-processing, main product production, distribution, and end of life and recycling. The use phase - the electricity that charges the battery in service - is deliberately outside the balance: it depends on the grid of the country of use, not on the product.
Article 7(1) binds the declaration to the combination of battery model and manufacturing plant. Two plants building the same model need two declarations, because electricity mix, transport routes and scrap rates differ. That is exactly why the geographical location of the plant is an explicit mandatory item - and why a group-wide average will not help later.
Article 7(1) lists what the declaration contains as a minimum. Four of the seven items are master data; three are the result of the calculation and its verification.
| Item | Information | Why it is there |
|---|---|---|
| a | Administrative information on the manufacturer | Who owns the declaration - the economic operator, not the plant |
| b | Information on the battery model | The model identifier under Art. 3(19), the same one used in the passport |
| c | Geographical location of the manufacturing plant | The reason the declaration is granular per model and per plant |
| d | Carbon footprint in kg CO2e per kWh | The reference quantity is the total energy delivered over the service life |
| e | Breakdown by life-cycle stage | The four stages inside the system boundary of Annex II point 4 |
| f | Identification number of the EU declaration of conformity | Ties the carbon figure to the battery's conformity assessment |
| g | Web link to the public version of the study | The calculation must stay traceable, not just the result |
Item (g) deserves attention: what is required is not only the result but a permanently reachable link to the public version of the study. The carbon figure is meant to stay verifiable rather than float as an isolated number. Organisations commissioning studies today should settle the publishable version in the contract - renegotiating it later costs more.
Two boundaries matter, because they affect entire business models: the category and the life cycle.
Article 7 names electric vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries. Portable and starter batteries are not on that list - and they need no battery passport either.
The "more than 2 kWh" threshold is a real boundary, not a rule of thumb. It also decides the passport duty - see Industrial batteries.
Article 7(5) exempts prepared, repurposed and remanufactured batteries from all three stages, provided they were already on the market before. A repurposer cannot possibly know the manufacturing footprint.
An exemption under Article 7(5) removes the duty, not the question. A passport in which the carbon block is simply absent is indistinguishable from one where the value was forgotten. The clean answer is a stated condition: the field is there, with its reason. The same logic applies to every conditional field in the passport.
"Does not apply yet" is no reason to wait. The delegated act will fix the methodology, not deliver the data - and gathering the data is the long part.
Electricity and heat consumption per manufacturing plant, with evidence of its origin. The declaration is drawn up per plant, so a group-wide average will not do later.
Cells, cathode material and metals dominate the total. What matters is not only the figure but who supplied it and when.
Without a defensible cycle count there is no denominator. Document the assumption, because it moves the result more than most emission items do.
The declaration is checked by an independent body. Slots at notified bodies get scarce the moment a deadline becomes real.
The buffer is also smaller than it looks. The Commission holds out more than a year after adoption; Article 7(1) names twelve months for electric vehicle batteries and 18 months for industrial batteries. Inside that window, primary data from several supply tiers has to come together, the calculation has to stand, and the verification has to be finished. Starting when the act arrives means starting too late.
A hard-coded carbon deadline would be wrong in every variant. So applicability lives with us as data, not as code - switchable on the day the act appears.
How the evidence chain is secured technically is covered in Audit trail & data integrity. For the full set of deadlines in the regulation see EU Battery Regulation 2023/1542, and what additionally has to happen at the registry from February 2027 is explained in Registering a battery passport: the EU DPP registry.
Batteriepasswerk carries the Article 7 items as dedicated fields with data-driven applicability - visible and fillable today, switched live on the day the delegated act enters into force.
