Carbon Footprint of Batteries: The Declaration Behind the Passport

The battery passport that starts on 18 February 2027 is the visible part. Behind it sits a number that must exist before any passport can be filled in: the battery’s carbon footprint, declared for each battery model per manufacturing plant. Article 7 of Regulation (EU) 2023/1542 builds it in three steps — declare, classify, cap — each with its own dates. This page reads them at the source.

Per model, per plant — no company average

For electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh and LMT batteries, a carbon footprint declaration shall be drawn up for each battery model per manufacturing plant (Article 7(1)). The granularity is the point: the same model built in two plants has two footprints, because its energy, materials and suppliers differ — a group average would hide exactly what the rule exposes. Until it becomes accessible via the QR code in Article 13(6) — the code that also opens the passport — the declaration shall accompany the battery.

What the declaration must contain

Article 7(1) sets the minimum content, points (a) to (g):

The calculation is not free-form. The Commission must establish the methodology for calculation and verification by delegated act, in accordance with the essential elements in Annex II, and the format of the declaration by implementing act — the Regulation sets the adoption deadlines itself, from 18 February 2024 for EV batteries to 18 February 2029 for industrial batteries with external storage. And the study behind the numbers must be public: a figure without its study is not a declaration.

The dates are a formula, not a headline

The declaration applies per category, and in every case from the later of the two dates the Regulation names:

Battery category	Declaration applies from
Electric vehicle batteries	18 February 2025, or 12 months after the methodology and format acts enter into force, whichever is the latest
Rechargeable industrial batteries, except those with exclusively external storage	18 February 2026, or 18 months after those acts enter into force, whichever is the latest
LMT batteries	18 August 2028, or 18 months after those acts enter into force, whichever is the latest
Rechargeable industrial batteries with external storage	18 August 2030, or 18 months after those acts enter into force, whichever is the latest

Quoting “February 2025” without the condition misreads the law: the operative date is the later one. What does not wait is the data work — supplier, energy and process data per plant cannot be collected in the month the duty lands.

Step two: the performance class. Step three: the cap

Declaration is only the first step. Under Article 7(2), the batteries in scope must bear a conspicuous, clearly legible and indelible label indicating the carbon footprint and declaring the carbon footprint performance class of the relevant model per plant; the technical documentation (Annex VIII) must demonstrate the calculation. The class requirements apply on the same conditional logic — headline date or 18 months after the relevant acts, if later: from 18 August 2026 (EV), 18 August 2027 (rechargeable industrial, except exclusively external storage), 18 February 2030 (LMT) and 18 February 2032 (external storage). The Commission reviews the classes and their thresholds every three years.

Then the obligation hardens into a limit: under Article 7(3), the technical documentation must demonstrate that the declared value for the model per plant is below the maximum threshold set by delegated act — from 18 February 2028 (EV), 18 February 2029 (industrial), 18 August 2031 (LMT) and 18 August 2033 (external storage), or 18 months after that act, if later.

Two boundaries: paragraphs 1 to 3 do not apply to a battery already placed on the market before preparation for re-use, repurposing or remanufacturing (Article 7(5)); and by 31 December 2030 the Commission must assess extending the declaration to portable batteries and the threshold to smaller industrial batteries (Article 7(4)).

How the declaration feeds the passport

From 18 February 2027, the battery passport under Article 77 carries the carbon footprint information among its data (Annex XIII): the headline value, its breakdown by life cycle stage and, once the class rules apply, the performance class. The passport displays the figure; the declaration — and the public study behind it — is where it is produced and can be checked. A passport is only as credible as the calculation it carries. The passport duty itself is in our guide to the battery passport from February 2027.

What battery makers should do now

• Fix the unit of work: one declaration per model per plant — collect data plant by plant, not as a corporate estimate.
• Pull the life cycle data in: raw materials sit with suppliers, production energy with the plant; distribution and end-of-life assumptions must be documented, not improvised.
• Keep the study publishable: quality and confidentiality are settled before the public link goes live, not after.
• Track the acts, not the headlines: build the calendar on the “whichever is the latest” formula.

How Ledger Consortium helps

Ledger Consortium aggregates the product data held by you and your suppliers — including the plant-level data this declaration is built from — anchors each passport record on a governed blockchain, timestamped and tamper-evident, and keeps it updated as the rules evolve. Anchoring proves a record existed and has not been altered; it does not certify that the data a client supplied was true — the declared footprint remains the responsibility of the operator placing the battery on the market. Predictable costs, no token or crypto exposure, GDPR- and eIDAS-aligned. In Italy, the Ledger DPP is distributed by Il Sole 24 Ore (Valore24), whose channel onboards dozens of companies per month. See a working passport in our live demo and browse News.