Document represents methodological guidelines for calculating the carbon footprint of industrial batteries (CFB-IND)Its aim is to provide a basis for enforcing the requirements set out in Article 7. Regulation (EU) 2023/1542 (Battery Regulation), which sets out the methodology for calculating and verifying the carbon footprint of batteries. This report focuses on industrial batteries with exclusively internal energy storage and with an energy storage capacity > 2 kWh.
The document builds on the previous JRC draft report, which was distributed in June 2024 as a basis for a second stakeholder consultation. The aim was to achieve maximum harmonisation with the draft delegated act on the carbon footprint methodology for electric vehicle batteries (DA-EV proposal)Stakeholder comments on both proposals were taken into account.
Main differences from the DA-EV design relate to the definition of system boundaries and functional unit:
- A distinction is made between custom batteries (CM) a standard (OtS) batteries, which does not exist for electric vehicle batteries.
- The functional unit is linked to the performance parameters to be declared under Article 10 of Regulation (EU) 2023/1542, namely the declared cycle life for rechargeable batteries (REP) and the declared life in years for on-demand batteries (OND).
- Several have been introduced new default recycling models due to the broader scope of CFB-IND, which also covers other relevant industrial battery chemistries such as lead-acid, nickel-cadmium and sodium-sulfur batteries.
A message recommends a consistent approach to determining CFB-IND and will serve as a technical basis for further policy decisions on the final method.
Document scope aims to calculate the carbon footprint of rechargeable industrial batteries with a capacity above 2 kWh, excluding batteries with exclusively external storage. The CFB-IND is to be declared for all industrial batteries falling within the scope of Article 7 of the Regulation, regardless of their chemical composition and specific use. The scope excludes batteries that have undergone preparation for reuse, preparation for other use, other use or reconditioning and that have already been placed on the market or put into service before these operations.
Functional unit is defined depending on the type of industrial battery:
- For rechargeable batteries (REP) is a functional unit 1 kWh of total energy delivered by the battery over its lifetimeFor standard (OtS) REP batteries the total energy is calculated as the product of the initial usable energy capacity and the expected cycle life (FEqC). For custom (CM) REP batteries the total energy is taken from the customer's technical specification (TPS).
- For on-demand (OND) or backup batteries is a functional unit ability to provide 1 kW min of backup power at any time throughout the battery's lifeFor standard (OtS) OND batteries the total backup service (PBU) is calculated as the product of the backup capacity (P·tse) and the years of operation. For custom (CM) OND batteries the PBU is calculated similarly, but using the values specified in the TPS and the Audit Technical Specification (ATS).
System boundaries define which parts of the product life cycle and related processes belong to the analyzed system. For CM batteries The system boundaries include all components delivered to the customer under the ATS, including spare parts required during the specified service life. For standard (OtS) batteries The system boundaries include all components physically contained within or permanently attached to the battery enclosure. The battery usage phase is expressly excluded from the system boundaries.
Cut-off rules allow certain processes, such as capital goods production, packaging material production and external components that are not essential for the safe and reliable operation of the battery, to be excluded from the modelling. A general cut-off of 1 % mass for material inputs per component can be used.
Data collection and data quality requirements: CFB calculation requires life cycle data (LCI) a activity dataThey are distinguished mandatory company-specific processes (main product production and distribution) and optional company-specific processes (most relevant and others). For mandatory company-specific processes Data from suppliers is required. For most relevant optional processes (e.g. production of cathode active material precursors) specific requirements are set for the selection of secondary or company-specific data depending on the availability and quality of the data. Company-specific data sets must meet specific requirements for format, nomenclature and metadata. It is established procedure for calculating the data quality rating (DQR) for the declared carbon footprint and for company-specific data sets.
Modeling requirements:
- Electrical power modeling should be aligned with the requirements in the final DA-EV for CFB-EV.
- Allocation is solved in the case of multifunctional processes with a hierarchy of methods (prevention of division, physical relationship, economic allocation).
- Recycled content and end-of-life (EoL) modeling are governed by circular footprint formula (CFF). Default recycling models are defined for different battery chemistries (Li-ion, NiMH, NiCd, lead, Na-S) and default CFF parameter values. It allows modeling of company-specific recycling processes under certain conditions.
- Transportation at different stages of the life cycle requires the use of company-specific data for cargo quantity and transport distance combined with secondary data on the transport mode.
Verification: The notified body verifies that the declared carbon footprint meets the requirements. Required documentation, which includes public version of the CFB supporting study (containing meaningful information for consumers) and non-public version of the CFB supporting study (with a detailed description of all calculation steps).
In conclusion, this report presents a detailed framework for determining the carbon footprint of rechargeable industrial batteries and is designed as technical basis for further development of delegated acts under Article 7 of Regulation (EU) 2023/1542. It is the result of a two-year consensus-building process among stakeholders and seeks to represent best practice. Spring
Glossary of key terms
- Active material: The materials inside a battery cell that react chemically to produce electrical energy when discharging or store energy when charging.
- Audit Technical Specification (ATS): Technical specification issued by the battery manufacturer, provided to the customer together with the delivered battery, describing the exact characteristics of the delivered battery and referring to the requirements of the final TPS.
- Battery: Any device supplying electrical energy generated by the direct conversion of chemical energy, with internal or external storage, consisting of one or more non-rechargeable or rechargeable battery cells, modules or assemblies thereof.
- Bill of materials (parts list): A list of raw materials, subassemblies, subassemblies, subcomponents and parts and their quantities required to manufacture the battery.
- Carbon footprint: The sum of greenhouse gas emissions and greenhouse gas removals in a product system, expressed as carbon dioxide equivalents and based on an assessment of the Product Environmental Footprint.
- End of service life: The state of a battery in which it is deemed unfit to continue providing service in its primary application due to aging or other degradation processes and is discarded or disposed of.
- Final useable energy capacity: The energy available to the user when discharging a fully charged battery at the end of its life within the charge/discharge limits set by the battery management system under standard operating conditions.
- Full equivalent cycles (FEqC): The number of times a battery could theoretically discharge its initial usable energy capacity.
- Functional unit: Qualitative and quantitative aspects of the functions, services, or both, provided by the battery.
- Life Cycle Assessment (LCA): Compilation and evaluation of inputs, outputs and potential environmental impacts of a product system throughout its life cycle.
- Off the Shelf (OtS): Batteries produced in series or batches of the same configuration and sold to the client without certainty about their final application or use profile.
- On-demand (OND): Batteries that are cycled only occasionally or never, their main function is the ability to provide power for a short period of time, such as in the event of a power outage.
- Repetitive Energy Supply (REP): Batteries that are primarily designed to regularly discharge their energy capacity, leading to more or less frequent cycling.
- System boundary: It defines which aspects are included or excluded from the life cycle study, including the life stages and processes required to fulfill the function defined by the functional unit.
- Technical Purchasing Specification (TPS): A technical specification issued by a customer containing application requirements for a custom-made (CM) battery.



