REGULATIONSBATTERY

Batteries Regulation

A non-EU manufacturer’s duties land on you as the importer. Due-diligence duties apply only above EUR 40M net turnover.

FALLS ONSUPPLIERBUYER

This one falls on you directly.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a spec sheet. A declaration you sign, backed by a technical file and, for several claims, third-party verification.

WHO SIGNS IT OFF
Cell and module suppliers must give you the compliance information free of charge. You place the CE mark and the declaration of conformity, and from February 2027 the QR resolves to the passport.
REQUIRED ARTIFACT · BATTERY6 ELEMENTS
EU declaration of conformity + carbon footprint declaration
REG. (EU) 2023/1542 · ART. 7, 18 · ANNEXES II, VIII
Carbon footprint per model, per plantkg CO2e per kWh over the declared lifetime, for each manufacturing plant.
Recycled contentCobalt, lithium, nickel and lead, documented per model.
Restricted substancesMercury, cadmium and lead within the Annex I limits.
Due diligence policyFor cobalt, lithium, nickel and natural graphite, third-party verified.
Technical documentationThe Annex VIII file standing behind the declaration.
Battery passport dataReachable by QR, per battery, from 18 February 2027.
THE CHARACTERISTIC FAILURE

A product LCA arrives, and it carries a carbon number.

What arrives covers the product. What is required covers the plant.

WHAT USUALLY ARRIVESINSUFFICIENT
Product life-cycle assessment
ISO 14040/44 · CRADLE-TO-GRAVE · PRACTITIONER-CHOSEN BOUNDARY
Complete, methodologically sound, third-party reviewed
Boundary and functional unit chosen by the practitioner
One figure for the model, not per manufacturing plant
NOT SUFFICIENT
A rigorous LCA on its own terms. The Batteries Regulation prescribes its own calculation rules and its own declaration format.
WHAT THE REGULATION NAMESSUFFICIENT
Carbon footprint declaration
PRESCRIBED METHOD · PER MODEL, PER PLANT · NOTIFIED BODY
kg CO2e per kWh, on the method the delegated act sets
Per model and per manufacturing plant, not averaged
Verified by a notified body before the claim is made
SUFFICIENT
Same cells, same supply chain — calculated the way the regulation requires it to be calculated.
THE DELTA: A CHOSEN LCA BOUNDARY VS THE PRESCRIBED CALCULATION METHOD
NEXT MILESTONE · BATTERY
LAST VERIFIED 9 AUG 2026
175DAYS
NOT YETAPPLIES 18 FEB 2027
Digital battery passport required

Each industrial and EV battery placed on the market needs a passport carrying carbon footprint, material origin and recycled content.

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Find out which of your battery suppliers can produce a carbon footprint per model per plant.

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