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Eu's new battery Law: Updated rules for Calculating the carbon footprint of industrial batteries

2025-07-11

Carbon Footprint Knowledge

The European Union’s Product Environmental Footprint (PEF) methodology is progressively influencing global trade patterns, especially in the battery industry. According to the new Battery Regulation, batteries exported to the EU market must use the EU PEF method for carbon footprint calculation and certification. This requirement not only increases corporate compliance costs but also has profound impacts on global value chains, potentially becoming a major barrier in future international trade. Below is an overview of the carbon footprint calculation rules for industrial batteries (excluding external storage):

Scope

Batteries are categorized as off-the-shelf (OtS) and custom-made (CM), and the new version distinguishes between these two types. OtS batteries are designed based on assumed average-use scenarios, which means their actual load characteristics are largely unknown before testing. In contrast, CM batteries are designed for specific applications and their load profiles are defined in advance. Therefore, calculation rules differ between OtS and CM batteries. Moreover, the new rules cover batteries with chemical compositions such as lead-acid, nickel-cadmium, sodium-ion, and high-temperature sodium-sulfur.
The distinction between CM and OtS batteries is defined as follows: CM batteries are designed and developed according to the customer’s Technical Purchasing Specifications (TPS) for a particular location and application. To qualify as CM, manufacturers must provide supporting evidence in the carbon footprint declaration’s supporting study, including the final customer’s TPS and the Auditable Technical Specification (ATS) delivered with the battery—such as an auditable battery configuration report. The TPS must clearly reflect the exact configuration agreed upon in a purchasing or equivalent contract, and the ATS must reflect the delivered battery’s exact configuration and parameters. Both must be explicitly referenced in the contract.
OtS batteries are produced in batches or series with a uniform configuration and without a predefined final application. They are designed based on typical use cases defined by the manufacturer, such as home storage systems or large container systems.
Companies must provide documentation that clearly indicates whether a battery is OtS or CM. For CM batteries, they must provide the customer’s TPS and the ATS delivered alongside the battery, such as the battery configuration report, proving that the battery is intended for a specific location and application and that such specifications are explicitly mentioned in the contract. Additionally, companies should clarify the battery’s purpose—whether it provides repetitive energy supply (REP) or on-demand/standby service (OND). For OND batteries, technical documentation must state this, and actual application must ensure that the battery’s full equivalent cycles (FEqC) do not exceed 40 cycles per year.

Calculation Rules

Both CM and OtS rechargeable industrial batteries can provide two different types of service:
They may provide repetitive energy supply, which means discharging previously stored energy on a regular basis, involving varying frequencies of charge-discharge cycles. These systems are classified as REP batteries.
Alternatively, batteries may provide standby or on-demand service, remaining fully charged most of the time and only discharging in rare situations such as power outages. In extreme cases, if the grid never fails, the battery remains unused throughout its life. Such systems are called OND batteries. To be classified as OND, technical documentation must explicitly declare this, and actual usage must ensure FEqC ≤ 40 annually.
Different functional units are defined for REP and OND batteries. REP battery footprints are reported as kilograms of CO₂-equivalent per kilowatt-hour (kg CO₂-eq/kWh) of energy delivered across the battery’s lifecycle. OND battery footprints are reported as kilograms of CO₂-equivalent per kilowatt-minute per year (kg CO₂-eq/kW·min·y) based on total standby service delivered over the lifecycle. All results should retain two significant digits.
According to Article 10 of the new Battery Regulation, industrial battery lifecycle parameters—especially expected cycle life for REP batteries and expected service life for OND batteries—must be declared. Since precise standards for these Article 10 parameters are not yet defined, the calculation rules provide reference definitions to minimize variability in declarations. These definitions align as much as possible with current standardization efforts and forthcoming durability legislation. Key parameters of expected lifespan must be disclosed in the publicly available supporting study to ensure their transparency and credibility.
Companies must provide lifecycle parameters required under Article 10, such as REP batteries’ expected cycle life and OND batteries’ expected years of service. For OND batteries, companies must also provide supporting data to calculate the total standby service (as defined in Section 3.2).

System Boundary and Cut-Off Rules

Industrial battery systems vary in design, often requiring additional or external components or replacement parts, which must be included in the system boundary. A distinction is maintained between CM and OtS batteries. CM batteries rely on specifications that include all relevant components designed to meet customer needs. Disclosure of baseline specifications to the certification body and provision of key parameters in the public version of the carbon footprint declaration (CFB) supporting study ensure traceability and verifiability.
Regarding lifecycle stages and cut-off rules, the methodology aligns closely with the Carbon Footprint for Battery-Electric Vehicle (CFB–EV) rules, as the principles are similar. However, the broader scope of CFB–IND and inclusion of additional chemistries such as Pb‑A, Ni‑Cd, or Na‑S necessitate consideration of extra materials and components.

Data Collection and Quality Requirements

Data collection procedures for system boundaries are essentially the same as those specified for CFB–EV, with additional materials required for multiple battery chemistries. As with EV batteries, data is categorized into mandatory company-specific processes (all processes in the manufacturing lifecycle stage) and non-mandatory company-specific processes. Non-mandatory processes are further distinguished between most relevant and less relevant.
Companies must provide detailed descriptions of the battery system boundary, especially for configurations involving additional or external components or replacement parts.

Modeling Requirements

Modeling requirements differ from the CFB–EV draft mainly in the recycling model and cyclical footprint formula due to additional chemistries. Stakeholder input, literature reviews, and expert consultation informed the development of specific default recycling models. These models, representing current industry averages, are provided in tabular form in Section 6.3 of the calculation rules and are consistent with the conservative CFB–EV methodology. The default recycling rate is set at 95%, based on EU law requiring 95% of batteries to be recycled at end-of-life. While the cyclical footprint formula remains unchanged, modeling for secondary materials has been added.
Given that industrial battery carbon footprint rules come after end-of-life battery management requirements, companies should already have EPR registration and producer responsibility organization (PRO) systems for recycling. Therefore, EoL (end-of-life) modeling for industrial batteries should be clear. Companies must obtain detailed downstream data from PROs to support the recycling model and secondary material management, enabling use of the Carbon Footprint Formula (CFF) to compute downstream footprint.

Verification

Verification procedures and requirements are the same as those for CFB–EV, with no additional or different obligations. However, there are important differences regarding the content and public version of the CFB supporting study. Manufacturers must provide both, due to differing functional units and the need to disclose key lifetime parameters (cycle life, available energy, reference testing) for transparency.

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