The EU Battery Regulation (Regulation (EU) 2023/1542) is a framework that regulates the entire battery lifecycle, gradually introducing Product Carbon Footprint (PCF) declarations, performance classes, maximum thresholds, recycled content, and a digital Battery Passport. The European Commission's battery webpage explains that the new regulation entered into force on August 17, 2023, with implementation through delegated and implementing acts starting from 2024. Battery material manufacturers, automotive OEMs, and Tier 1 suppliers outside the EU will be required to provide data when their customers place batteries on the EU market.
First, it is necessary to distinguish between the dates. The PCF declaration under Article 7 is a mechanism for declaring kgCO2e/kWh for each battery model and manufacturing facility, covering EV batteries, rechargeable industrial batteries over 2kWh, and LMT batteries. Article 7 in EUR-Lex stipulates the dates for EV batteries as February 18, 2025, or 12 months after the entry into force of the relevant acts, whichever is later; for rechargeable industrial batteries (excluding those exclusively for stationary storage), February 18, 2026, or 18 months later; and for LMT batteries, August 18, 2028, or 18 months later. Conversely, February 18, 2027, is a key milestone for the digital Battery Passport/QR code obligation for EV, LMT, and industrial batteries over 2kWh, and is not the actual start date for PCF declarations.
PCF Declaration
Based on Article 7, start dates vary by battery category. Check the entry into force dates of delegated and implementing acts.
Performance Classes
Requirements such as A–E labels will be introduced in stages, starting from August 2026 for EV batteries and August 2027 for industrial batteries.
Battery Passport
From February 18, 2027, digital information provision via QR codes will be required for EV, LMT, and industrial batteries over 2kWh.
The target categories are LMT (light means of transport, such as e-bikes and e-scooters), EV batteries, and rechargeable industrial batteries over 2kWh. PCF is not just factory emissions; it requires a data design similar to LCA, including raw material procurement, precursors and active materials, cell manufacturing, module and pack assembly, transportation, and end-of-life disposal and recycling. ISO 14067:2018 outlines the requirements for quantifying and reporting product CFP, and the GHG Protocol Product Standard provides a benchmark for understanding total product lifecycle emissions. In the EU, alignment with the Product Environmental Footprint (PEF) methodology and the specific PEFCR for batteries is also required.
The most critical aspect of the calculation is understanding the emission ratio by process. The European Commission Joint Research Centre (JRC) technical report on battery supply chains analyzes bottlenecks in lithium-ion battery critical raw materials, processed materials, components, and cell manufacturing. In practice, emission sources are divided into raw material mining and refining; material processes such as cathode and anode materials; energy-intensive cell manufacturing; and pack assembly. Cell manufacturing is particularly sensitive to power grid emission factors; therefore, the PCF for batteries with identical specifications can vary between China, South Korea, Japan, and Europe.
In relation to the Battery Passport, information such as PCF values, recycled content, performance and durability, declarations of conformity, and manufacturer information will be referenced by individual unit or model. While the QR code is displayed on the final product, material manufacturers must be prepared to pass primary data, emission factors, facility-specific power data, lot boundaries, and verification audit trails downstream. With February 2027 serving as the "official start of data integration," companies should complete preliminary calculations, audits, and adjustments to customer-specific formats for PCF well in advance.
There are three implications for suppliers. First, PCF is directly linked not only to Scope 3 Category 11 (use of sold products) but also to the customer's Category 1 (purchased goods and services). Second, whether low-carbon power from renewable energy certificates or PPAs is accepted under market-based methods must be verified according to each battery PCF methodology. Third, OEMs do not require average values but rather verifiable data that specifies the manufacturing facility, battery model, and target period. Initially focusing on three key products to establish a PCF template that fixes BOM, weight, energy consumption, yield, and transportation conditions will reduce the risk of procurement discontinuation from 2027 onwards.