Calculating Carbon Footprint for Industrial Batteries (>2 kWh): A Practical Guide

Industrial batteries over 2 kWh sold in the EU now need a Carbon Footprint Declaration, as per Article 7 of Regulation (EU) 2023/1542. Using the JRC methodology (Report JRC141282, May 2025), manufacturers can calculate emissions from raw materials to recycling and report them through the Digital Battery Passport. 

Based on the latest Joint Research Centre (JRC) methodological support (Report JRC141282, published May 2025) and the EU guidelines, here is a comprehensive guide on how to perform these calculations. This guide is intended for manufacturers and compliance teams that already understand the regulatory obligation and now need practical clarity on how to collect data, manage supplier inputs, and operationalise carbon footprint reporting through the Digital Battery Passport.

Understanding the Scope  of Regulation (EU) 2023/1542 & JRC Methodology

The requirement applies to rechargeable industrial batteries with a capacity above 2 kWh. The initial step is the carbon footprint declaration, followed by classification by performance and, eventually, maximum lifecycle thresholds. The use phase, the electricity consumed by end-users to charge the battery, is excluded, so the focus remains on the manufacturer’s supply chain and design. 

As performance classes are introduced through delegated acts, carbon footprint results will no longer be viewed in isolation. Batteries will be ranked relative to one another, meaning conservative assumptions, poor data quality, or late supplier engagement today can translate into weaker performance classes tomorrow. 

In effect, manufacturers are not only reporting emissions, but they are also competing on carbon intensity to secure future EU market access.

The Joint Research Centre (JRC) provides a standardised methodology to calculate and verify carbon footprints, covering batteries used in:

• Home storage systems (solar or renewable energy)
• UPS systems for hospitals and data centres
• Medical equipment and industrial machinery
• Electrified transport (ships, trains, aircraft)
• Large container-based energy storage for electricity grids

The goal of this approach is to promote low-carbon batteries in the EU, ensure transparent reporting, and support market competitiveness while maintaining environmental accountability.

The Compliance Roadmap: 2026–2030 Deadlines

• Feb 2026: Mandatory Carbon Footprint Declaration begins for industrial batteries (>2 kWh).
• Aug 2027: Mandatory Performance Classes (A-G) are assigned based on reported data.
• Feb 2027: The Digital Battery Passport becomes mandatory for all industrial batteries.
• Feb 2030: Maximum Carbon Thresholds apply. Batteries exceeding the limit will be barred from the EU market.

The Functional Unit: How to Measure

The carbon footprint is measured in kilograms of CO₂ equivalent per 1 kWh of energy delivered over the battery’s service life.

Carbon Footprint (kg CO₂e/kWh)
= Total lifecycle emissions ÷ (Nominal capacity × Expected cycle life)

This value represents how much CO₂ is emitted for every 1 kWh of energy the battery delivers over its usable life. By using this functional unit, carbon performance is directly linked to battery durability and lifetime energy delivery, rather than manufacturing emissions alone.

Note: For backup or on-demand batteries (such as UPS systems), the JRC methodology may apply a time-based functional unit instead of charge–discharge cycles. This reflects real-world operating conditions for batteries that are rarely cycled.

Step-by-Step Calculation Methodology

The EU applies the Product Environmental Footprint (PEF) methodology, structured across four lifecycle stages:

1. Raw Material Acquisition and Pre-processing

Covers the mining and refining of lithium, cobalt, nickel, graphite, and other relevant materials.

• Primary data is preferred for key materials
• Where unavailable, EU-approved secondary datasets (EF 3.1 or later) must be used

Implementation reality: Secondary datasets are typically more conservative. Limited access to Tier-2 and Tier-3 supplier data can therefore increase reported emissions and influence comparative performance.

2. Manufacturing

Includes cell, module, and battery assembly.

• Primary data on energy use and waste is mandatory
• Electricity mixes should reflect site-specific consumption or recognised contractual instruments (REGOs/GOs), where applicable

3. Distribution

Accounts for transport to the EU point of sale, considering mode of transport (ship, rail, road) and distance travelled.

4. End-of-Life and the Circular Footprint Formula (CFF)

The Circular Footprint Formula (CFF) accounts for both the burdens and benefits of recycling. It balances emissions from end-of-life processing against the environmental benefits of using recycled materials in production.

Key parameters include:

• R₁ (Recycled content): Share of recycled material used as input
• R₂ (Recycling rate/yield): Proportion of material effectively recovered at end-of-life
• A-factor (Allocation factor): Determines how recycling benefits are shared between producers and recyclers, depending on the material

Accurate documentation of recycled content, recycling processes, and recovery efficiencies is essential to ensure correct and consistent application of the CFF.

Data Quality Requirements

The JRC emphasises Data Quality Indicators (DQI) to ensure reliable results:

• Technological Representativeness: Reflects the actual battery chemistry (LFP, NMC, Lead-Acid).
• Geographical Representativeness: Energy mix corresponds to the correct region.
• Time-related Representativeness: Data should be from the last 3–5 years.

Implementation reality: In most organisations, carbon footprint calculations sit at the intersection of sustainability, engineering, procurement, and compliance. The first bottleneck is rarely methodology; it is aligning internal data ownership and supplier inputs in a consistent format. 

Teams that rely on spreadsheets often struggle with version control, audit trails, and late supplier responses. When carbon footprint reporting is treated as a shared, system-supported workflow rather than a one-off study, organisations are better positioned to scale verification and avoid delays as requirements tighten.

Verification and Declaration

Once calculations are complete, manufacturers must ensure proper verification for ethical sustainability claims:

• A Notified Body must audit and validate the study and technical documentation.
• A public version of the study must be accessible via a web link.
• The data will be integrated into the Digital Battery Passport, with a QR code on the battery label for accessible traceability.

At this stage, the Digital Battery Passport becomes a critical infrastructure layer. Rather than acting as a static disclosure, it enables continuous data updates, supplier contributions, and audit-ready traceability, reducing reliance on one-off studies and manual documentation.

Conclusion

As carbon footprint verification approaches, many organisations are piloting Digital Battery Passport platforms to structure data collection, supplier onboarding, and audit readiness ahead of formal deadlines.

Solutions such as DigiProd Pass enable manufacturers to manage carbon footprint data, supplier inputs, and verification evidence within a single, traceable system, reducing reliance on spreadsheets and supporting scalable compliance as performance classes and thresholds are introduced.

FAQs

1. Is carbon footprint reporting mandatory for industrial batteries in the EU?

Yes. Regulation (EU) 2023/1542 requires all rechargeable industrial batteries above 2 kWh to include a verified carbon footprint declaration for EU market access.

2. Which batteries are considered industrial batteries over 2 kWh?

These are rechargeable batteries used in UPS systems, industrial machinery, medical equipment, home or containerised energy storage, and grid-scale energy applications with a capacity exceeding 2 kWh.

3. Does the carbon footprint include electricity used during battery charging?

No. The “use phase” is excluded. The carbon footprint focuses on emissions from raw material acquisition, manufacturing, distribution, and end-of-life recycling.

4. How is the carbon footprint of industrial batteries calculated?

Manufacturers use the EU Product Environmental Footprint (PEF) methodology, following JRC guidance (Report JRC141282, May 2025), covering raw materials, production, distribution, and recycling stages.

5. How can customers and regulators access carbon footprint data?

Verified carbon footprint data is integrated into the Digital Battery Passport, accessible via a QR code on the battery label or through authorised digital systems.

6. Why is the Digital Battery Passport important for carbon footprint reporting?

It ensures transparency, compliance, and traceability across the battery lifecycle, linking verified environmental data to each battery for regulators, suppliers, and customers.

Sources

1. Regulation (EU) 2023/1542 on batteries – European Commission
2. Methodological support for calculating the carbon footprint of industrial batteries – JRC Report JRC141282, May 2025
3. Circular Economy Action Plan – European Commission
4. Product Environmental Footprint (PEF) – European Commission

‍