Carbon footprint (CF) disclosure has become one of the most influential levers in shaping a cleaner and more competitive battery industry. With the introduction of the EU Battery Regulation (EUBR), manufacturers are required to quantify, verify, and disclose the full carbon intensity of batteries placed on the European market. These requirements are reshaping how companies design products, operate facilities, and engage with suppliers. They also place carbon footprint calculation and performance classes at the centre of sustainability and compliance strategies.

The BASE Project supports this transition by providing digital tools that align with regulatory demands and help companies take meaningful action to reduce emissions. Understanding how carbon footprint is calculated, reported, and assessed is essential for meeting regulatory expectations and maintaining competitiveness in a fast-evolving industry.

Why Carbon Footprint Calculation Matters More Than Ever

Global demand for batteries continues to grow as transport electrification accelerates and renewable energy storage becomes mainstream. This rapid scaling has increased scrutiny on the climate impact of battery manufacturing, especially in upstream mining, refining, cell production, and logistics.

Carbon footprint calculation gives manufacturers the ability to track emissions across the entire lifecycle of a battery, from raw material extraction to cell manufacturing and distribution. It provides clarity on where emissions occur and supports decisions that reduce energy intensity. CF calculation has also become important for corporate sustainability reporting, as investors, regulators, and consumers expect verifiable evidence behind environmental claims.

With the help of accurate CF measurement, organisations can build cleaner supply chains, optimise energy use, and plan long-term decarbonisation strategies.

How the EU Defines Carbon Footprint for Batteries

The EU Battery Regulation sets clear rules on how the carbon footprint must be calculated. Under Regulation (EU) 2023/1542, CF disclosure is mandatory for electric vehicle batteries, industrial batteries above 2 kWh, and light means of transport (LMT) batteries.

The methodology is standardised to ensure consistency and comparability across the global value chain.

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Lifecycle-based assessment

Manufacturers must conduct a cradle-to-gate assessment. This means measuring emissions from raw material extraction through processing, manufacturing, and upstream logistics until the final product leaves the factory gate.

Mandatory verification

All CF declarations must be verified by an accredited third party before the battery is placed on the market.

Standardised methodology

The EU has introduced Delegated Regulation (EU) 2024/1294, which sets out rules on system boundaries, data quality, allocation methods, emission factors, and reporting formats.

This standardisation ensures that CF disclosures are comparable across organisations and regions, reducing the risk of inconsistent or misleading claims.

Carbon Footprint Metrics: What Manufacturers Must Report

The EU requires manufacturers to disclose four core metrics describing the carbon intensity of their battery production:

• First, companies must report the total cradle-to-gate carbon footprint in kg CO₂-equivalent per kWh of total energy delivered by the battery over its service life. This value is the foundation of performance class assessment.
  
• Second, manufacturers must provide a breakdown of emissions across lifecycle stages. This highlights which steps contribute most to carbon intensity, such as material refining or electrode production.
• Third, the share of primary and secondary materials used in the battery must be disclosed, along with how each contributes to overall emissions.
• Fourth, organisations must report the energy mix used in production. The use of renewable electricity is one of the most influential factors in reducing carbon intensity.

These metrics help regulators, customers, and supply chain partners understand how clean or carbon-intensive a battery is before it enters service.

Performance Class Requirements: A New Competitive Benchmark

Starting in 2027, batteries must comply with performance classes based on their cradle-to-gate CF values. The European Commission defines class boundaries that differentiate low-carbon, average, and high-carbon battery production.

Performance classes are designed to reward cleaner production practices and create a framework for comparing batteries based on environmental impact. Batteries with lower carbon intensity will have better class ratings, which can influence procurement decisions, regulatory approval, and consumer preference.

This system supports Europe’s commitment to sustainable manufacturing by encouraging the adoption of energy-efficient processes and greater use of renewable electricity. International suppliers selling into the EU must also meet these class requirements, which strengthens global alignment.

Performance classes will create new incentives for innovation, helping companies differentiate themselves on measurable sustainability achievements.

What Drives Emissions in Battery Production?

Understanding CF hotspots helps manufacturers plan long-term decarbonisation strategies. The most carbon-intensive stages typically include:

1. Material extraction and refining

Raw material extraction and refining often represent a large share of total emissions. Accessing and processing minerals such as lithium, nickel, cobalt, and manganese requires substantial energy and often relies on carbon-intensive grids.

2. Cell manufacturing

Cathode production, electrolyte synthesis, and electrode coating are energy-demanding processes, especially when powered by fossil-based electricity.

3. Heating, drying, and formation cycles

These stages consume considerable electricity and directly influence CF values.

Reducing emissions in these areas requires cleaner energy, improved efficiency, and greater use of recycled materials.

The Role of Renewable Energy and Recycled Content

Using renewable energy during production is one of the most effective ways to reduce the cradle-to-gate carbon footprint. Manufacturers located in regions with clean electricity grids benefit immediately, while others can switch to renewable energy procurement or on-site generation.

Recycled materials also play a growing role in reducing emissions. Secondary nickel, aluminium, and cobalt have a much lower carbon footprint compared to primary materials. As recycling infrastructure improves and closed-loop systems expand, manufacturers that integrate secondary materials will see substantial carbon reductions and improved performance-class results.

The increasing value of recycled content also aligns strongly with circular economy principles and supports long-term resource sustainability.

Implications for Supply Chain Strategy

CF disclosure obligations are influencing how companies plan their production and sourcing strategies. Many are considering the relocation of gigafactories to regions with reliable, low-carbon electricity. There is also growing demand for certified low-carbon materials from mining and refining operations.

Supplier audits are becoming more rigorous as companies seek accurate data to support compliance. This includes upstream verification and data sharing, especially for carbon-intensive materials and processes.

Recycling and closed-loop material flows are gaining strategic importance. Companies that integrate recycled content and build partnerships with recycling operators will be better prepared for future carbon reduction targets.

Early adopters of CF-oriented strategies are likely to gain competitive advantages, both in European markets and globally.

How the BASE Project Contributes to CF Transparency

The BASE Project contributes directly to the industry’s push for low-carbon and transparent battery production. BASE is developing a trusted and interoperable Digital Battery Passport framework that integrates carbon footprint information into its core architecture.

The Digital Battery Passport developed by BASE ensures that CF data is captured, verified, and accessible throughout the battery lifecycle. It provides structured fields for emissions data, supports harmonised reporting formats, and connects upstream suppliers with downstream users through secure and traceable data exchange.

BASE applies advanced analytics and blockchain-backed verification tools that help manufacturers identify emission hotspots, comply with the EU Battery Regulation, and demonstrate transparency to regulators and market partners.

By enabling standardised and trustworthy CF reporting, the BASE Project strengthens the foundation for a competitive, climate-aligned European battery industry.

Closing Thoughts

Carbon footprint calculation has evolved into a central requirement for compliance, sustainability, and competitiveness. The EU Battery Regulation is closely reshaping how batteries are designed, sourced, and manufactured, with performance classes becoming a key mechanism for rewarding cleaner production.

As the industry prepares for upcoming class thresholds and more advanced reporting requirements, companies that invest in accurate measurement, decarbonised supply chains, and transparent data sharing will be best positioned for long-term success.

As performance classes take effect and regulatory scrutiny intensifies, organisations that invest in precise measurement, cleaner supply chains, and transparent reporting will gain a significant advantage. CF-based competition is becoming one of the defining forces in the global battery landscape.

The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.

References:

Regulation (EU) 2023/1542 (EU Battery Regulation): https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng

Delegated Regulation (EU) 2024/1294 (CF methodology requirements): https://eur-lex.europa.eu/eli/reg_del/2024/1294/oj/eng

EU Green Deal Overview: https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en

European Commission: Sustainable Batteries Information: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en

European Environment Agency: Greenhouse gas emission intensity: https://www.eea.europa.eu/en/analysis/indicators/greenhouse-gas-emission-intensity-of-1

European Commission: Life Cycle Assessment Guidance: https://eplca.jrc.ec.europa.eu/lifecycleassessment.html