EU: New regulations for carbon footprint of electric vehicle batteries
The EU Commission has published two new draft regulations for carbon footprint methodology and declarations of electric vehicle batteries. They will both supplement the new Battery Regulation (EU) 2023/1542.
The first draft Commission Delegated Regulation concerns the rules on how to calculate the carbon footprint for the purposes of Article 7 of the Battery Regulation. It also contains rules for the verification of the carbon footprint calculation in the context of the conformity assessment.
The second Commission Implementing Regulation concerns the format of the carbon footprint declaration that is required by Article 7 of the Battery Regulation. The proposed format is tabular format, both in the case of a physically declaration and in the case of an electronic one.
Methodology for carbon footprint of electric vehicle batteries
The anticipated widespread adoption of batteries in sectors like transportation and energy storage is poised to drive down carbon emissions. To maximize this reduction, it’s imperative that these batteries have a low carbon footprint throughout their entire life cycle.
EU Regulation 2023/1542 outlines criteria for manufacturers to disclose the carbon footprint of specific battery types. According to these guidelines, the Commission must develop methodologies for calculating and verifying the carbon footprint of various battery categories, beginning with electric vehicle batteries.
Key aspects of the carbon footprint methodology mandate adherence to the Product Environmental Footprint (PEF) method specified in Commission Recommendation (EU) 2021/2279. The regulation expresses the carbon footprint of batteries as kg CO2 equivalent per kWh of total energy provided over the battery’s expected lifespan.
For electric vehicle batteries, the kWh output over their lifespan depends on factors like capacity, charging frequency, discharge rate, and durability. Charging frequency is determined by vehicle usage patterns rather than specific battery models, necessitating typical values for different vehicle categories. Battery durability considers both calendar and cycle aging, typically assessed based on the duration of the commercial warranty due to the lack of standardized tests.
The regulation’s essential components advocate a combination of company-specific and secondary data for accurate carbon footprint calculations while minimizing administrative burdens. Clear guidelines are needed on when to use company-specific versus secondary data, and under what circumstances a choice between the two is permissible. In cases where suppliers’ company-specific data are confidential, they must be shared with downstream operators in aggregated form to facilitate smooth carbon footprint calculations. Additionally, provisions should ensure that notified bodies and market surveillance authorities have access to all relevant data.
To find out more about EU battery regulation in China, please contact the Institute for Global Automotive Regulatory Research directly.