Carbon Footprint: What to Enter
The EU Battery Regulation requires every in-scope battery passport to declare the battery's lifecycle carbon footprint in kg COโe per kWh. This article explains what to enter, where the data comes from, and how the performance class works.
What the regulation requires
Article 7 of the Battery Regulation requires a carbon footprint declaration for EV batteries and industrial batteries above 2 kWh. The declaration must cover the full lifecycle: raw material extraction, manufacturing, transport, and end-of-life processing.
The value is expressed as kilograms of COโ equivalent per kilowatt-hour (kg COโe/kWh) of the battery's rated energy.
Where the data comes from
The carbon footprint value must be derived from a lifecycle assessment (LCA) conducted in accordance with the methodology defined by the European Commission's Joint Research Centre (JRC). The JRC methodology specifies:
- System boundaries (what to include in the calculation).
- Data sources (primary data from your production vs secondary data from databases).
- Allocation rules (how shared processes are attributed).
- Impact assessment method (the COโe conversion factors).
In practice, most manufacturers commission a third-party LCA provider (such as TรV, SGS, Bureau Veritas, or a specialist sustainability consultancy) to conduct the assessment and produce the certified figure.
What to enter in DPP Cloud
In the passport creation wizard, the Sustainability accordion section contains three carbon footprint fields:
- Carbon footprint (kg COโe/kWh) โ Enter the total lifecycle figure from your LCA. This is a numeric value, typically between 30 and 200 depending on the battery chemistry and manufacturing process. Required.
- Carbon footprint performance class โ A letter grade from A (best) to E (worst), based on how your battery's carbon footprint compares to the EU-wide benchmark. The Commission has not yet published the benchmark values, so this field is currently optional. When benchmarks are published, DPP Cloud will update to make it required.
- LCA methodology reference โ A text field for the LCA standard or methodology used (e.g., "JRC Product Environmental Footprint Category Rules for Batteries, v1.0"). Optional but recommended.
If you enter an estimated carbon footprint while your LCA is pending, DPP Cloud allows this for Draft passports. However, the activated passport must contain the verified figure from a completed lifecycle assessment. Estimated values that are not replaced will reduce your compliance strength score and may be flagged by market surveillance authorities.
Performance class
The carbon footprint performance class will rank batteries into classes A through E, similar to the energy efficiency labels used for appliances. The Commission will define the class boundaries by delegated act. Once published:
- Class A = significantly below the EU average carbon footprint.
- Class E = significantly above the EU average carbon footprint.
DPP Cloud will automatically calculate the performance class once the Commission publishes the benchmark values.
A full lifecycle assessment typically takes 3โ6 months. If you have not started, begin now to ensure you have a verified figure before you need to activate your passports. The LCA does not need to be repeated for each passport if the manufacturing process and supply chain remain the same โ one LCA per battery model is typically sufficient.
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EU Battery Regulation compliance โ 18 February 2027 deadline.