The European Commission has published a draft of two Delegated Regulations related to EU 2023/1542 (the New Battery Regulation), which are the calculation and declaration methods of the battery carbon footprint.

The New Battery Regulation sets out life-cycle carbon footprint requirements for different types of batteries, but the specific implementation was not published at the time. In response to the carbon footprint requirements for electric vehicle batteries that will be implemented in August 2025, the two bills clarify methods for calculating and verifying their life-cycle carbon footprint.

The two draft bills will have a one-month comment and feedback period from April 30, 2024 to May 28, 2024.

Requirements for carbon footprint calculation

The bill clarifies the rules for calculating carbon footprints, specifying functional unit, system boundary, and cut-off rules. This journal mainly explains the definition of functional unit and system boundary conditions．

Functional unit

Definition:The total amount of energy provided by the battery over the battery’s service life (E_total), expressed in kWh.

Calculation formula:

Therein

a) Energy capacity is the useable energy capacity of the battery in kWh at the beginning of life,namely the energy available to the user when discharging a new fully charged battery until the discharge limit set by the battery management system.。

b) FEqC per year is the typical number of full equivalent charge-discharge cycles per year. For different types of vehicle batteries, the following values should be used.

c) Years of operation is determined by the commercial warranty according to the following rules:

1. The duration of the warranty on the battery in years applies.
2. If there is no specific warranty on the battery, but a warranty on a vehicle in which the battery will be used, or parts of a vehicle that include the battery, the duration of that warranty applies.
3. By way of derogation of points i) and ii), if the duration of the warranty is expressed in both years and kilometres whichever one is reached first, the shortest number of the two in years applies. For this purpose, a conversion factor of 20.000 km equalling one year shall be applied for batteries to be integrated into light-duty vehicles; 5.000 km equalling oneyear for batteries to be integrated into motorcycles; and 60.000 km equalling one year for batteries to be integrated into medium-duty and heavy-duty vehicles.
4. If the battery is used in multiple vehicles and the results of the approach in point ii) and, where applicable, iii) would be different between those vehicles, the shortest resulting warranty applies.
5. Only warranties that are related to a remaining energy capacity of 70% of the useable energy capacity of the battery in kWh at the beginning of life or higher of its initial value shall be taken into account in points i) to iv). Warranties that explicitly exclude any individual components that are essential for the proper functioning of the battery or that restrict the use or storage of the battery apart from conditions that are within the typical use of such batteries shall not be taken into account in points i) to iv).
6. If there is no warranty or only a warranty not compliant with the requirements under point (v), a figure of five years shall be used, except for cases where a warranty is not applicable, such as where there is no transfer of ownership of the battery or vehicle, in which case the manufacturer of the battery shall determine the number of years of operation and justify it in the public version of the carbon footprint study.

System boundary

(1).Raw material acquisition and pre-processing

This life cycle stage covers all activities prior to the main product production stage, including:

l The extraction of resources from nature and their pre-processing until their use in product components entering through the gate of the first facility falling under the main product production life cycle stage.

l Transport of raw materials and intermediate products within, between and from extraction and pre-processing facilities until the first facility falling under the main product production life cycle stage.

l The production of the cathode active material precursors, anode active material precursors, solvents for the electrolyte salt, the pipes and the fluid for the thermal conditioning system.

(2).Main product production

This life cycle stage covers the manufacturing of the battery including that of all components that are physically contained in or permanently attached to the battery housing. This life cycle stage covers the following activities:

l Cathode active material production;

l Anode active material production, including the production ofgraphite and hard carbon from its precursors;

l Anode and cathode production, including the mixing of ink components, coating of ink on collectors, drying, calendaring, and slitting;

l Electrolyte production, including the electrolyte salt mixing;

l Assembling the housing and the thermal conditioning system;

l Assembling the cell components into a battery cell, including stacking/winding of electrodes and separator, assembling into a cell housing or pouch, injection of electrolyte, closing of cell, testing and electrical formation;

l Assembling the cells into modules/pack including electric/electronic components, housing, and other relevant components;

l Assembling the modules with electric/electronic components, housing, and other relevant components into a finished battery;

l Transport operations of the final and intermediate products to the site where they are used;

(3).Distribution

This life cycle stage covers the transport of the battery from the battery manufacturing site to the point of placing the battery on the market. Storage operations are not covered.

(4).End of life and recycling

This life cycle stage begins when the battery or the vehicle in which the battery is incorporated is disposed of or discarded by the user and ends when the battery concerned is returned to nature as a waste product or enters another product’s life cycle as a recycled input. This life cycle stage covers at least the following activities:

l Battery waste collection;

l Battery dismantling;

l Thermal or mechanical treatment, such as milling of the waste batteries;

l Battery cell recycling such as pyrometallurgical and hydrometallurgical treatment;

l Separation and conversion into recycled material, such as recycling of the aluminium from the casing;

l Printed wiring board (PWB) recycling;

l Energy recovery and disposal.

Note: The impacts of the transport of the waste vehicle to the vehicle dismantler, of the transport of the waste batteries from the vehicle dismantler to the disassembling site, of the pre-treatment of the waste batteries, such as extraction from vehicle, of discharging and sorting, and of the dismantling of the battery and its components, are not covered.

The following are not covered by any of the life cycle stages:manufacturing of capital goods, including equipment; production of packaging materials; any component, such as of the thermal conditioning system, not physically contained in or permanently attached to the housing; auxiliary inputs to manufacturing plants that are not directly related to the battery production process, including heating and lighting of associated office rooms, secondary services, sales processes, administrative and research departments; the assembly of the battery within the vehicle.

Cut-off rule:For the material inputs per system component, input and output flows with less than 1% mass can be neglected. In order to ensure mass balance, the missing mass needs to be added to the input flow of substances with the highest carbon footprint contribution in the relevant system components.

The cut-off may be applied in the raw material acquisition and pre-processing life cycle stage and in the main product production life cycle stage.

In addition to the above, the draft also includes data collection requirements and quality requirements. When the calculation of the carbon footprint is complete, meaningful information about the carbon footprint calculation also needs to be provided to consumers and other end users. It will be analyzed and interpreted in detail in a future journal.

Requirements for carbon footprint declaration

The format of the carbon footprint declaration should be as shown in the figure above, with the following contents:

l Manufacturer (including name, registration ID number or registered trademark)

l Battery model (identification code)

l Address of the battery manufacturer

l Life cycle carbon footprint (【quantity】kg CO2-eq.per kWh)

Life cycle stage：

l Raw material acquisition and pre-processing (【 amount 】kg CO2-eq.per kWh)

l Main product production (【 amount 】kg CO2-eq.per kWh)

l Distribution (【 amount 】kg CO2-eq.per kWh)

l End of life and recycling (【 amount 】kg CO2-eq.per kWh)

l Identification number of the EU declaration of conformity

l Web link giving access to a public version of the study supporting the carbon footprint values (any additional information)

Conclusion

Both bills are still open for comment. The European Commission has noted that the draft has not yet been adopted or approved. The first draft is merely a preliminary opinion of the services of the Commission and should not in any case be considered as an indication of the official position of the Commission.