Article 7 of the EU Batteries Regulation (Regulation (EU) 2023/1542) requires EV batteries, rechargeable industrial batteries over 2 kWh and LMT batteries to carry a carbon footprint declaration, a life-cycle figure in kg CO2e per kWh, calculated per battery model per manufacturing plant. Each category's start date is either a fixed date or a set period after the Commission's calculation-methodology acts enter into force, whichever is later, and because those acts have been delayed, the nominal dates in the regulation are not the live dates.
This page reflects the rules as of 10 July 2026. Regulatory dates are dated and may change, confirm against the current instruments or with qualified advisers.
The carbon footprint declaration is a distinct obligation under Article 7 of Regulation (EU) 2023/1542, separate from the battery passport, though the two connect later. It is drawn up for each battery model per manufacturing plant, so the same model made in two plants needs two declarations.
Article 7(1) sets the minimum contents: administrative information about the manufacturer; the battery model; the geographic location of the manufacturing plant; the battery's carbon footprint, calculated as kg of CO2 equivalent per kWh of the total energy the battery provides over its expected service life; that footprint broken down by life-cycle stage as described in Annex II, point 4; the identification number of the battery's EU declaration of conformity; and a web link to a public version of the study behind the figures.
Two details matter in practice. The denominator is total energy delivered over the battery's service life, not rated capacity, so expected lifetime and cycling assumptions shape the number. And until the declaration is accessible through the QR code referred to in Article 13(6), it must physically accompany the battery.
Article 7(5) exempts batteries that have undergone preparation for re-use, preparation for repurposing, repurposing or remanufacturing, provided the battery was already placed on the market or put into service before those operations.
The regulation does not give each category a simple deadline. For every category, Article 7(1) sets the application date as a nominal fixed date or a set period after the entry into force of two Commission acts, the delegated act establishing the calculation methodology and the implementing act establishing the declaration format, whichever is the latest:
The Commission's own deadlines to adopt those acts were 18 February 2024 for EV batteries, 18 February 2025 for rechargeable industrial batteries (except external storage), 18 February 2027 for LMT and 18 February 2029 for external-storage industrial batteries (Article 7(1), fourth subparagraph). The EV deadline was missed: a draft of the EV methodology delegated act was published for consultation in April 2024, but as of July 2026 the final EV acts had not been published in the Official Journal. Because the "whichever is later" clause governs, the nominal 18 February 2025 date for EV batteries has passed without the obligation applying; the clock starts only when the acts are in force, and EV manufacturers will then have 12 months (industrial manufacturers 18 months) from that point.
The honest reading for planning: none of the declaration dates above is settled until the methodology act for your category is adopted. Treat the nominal dates as floors, not deadlines, and confirm the live date for your category against the Official Journal before committing a compliance calendar.
The calculation rules are not in the regulation itself. Annex II of Regulation (EU) 2023/1542 sets the essential elements, a life-cycle approach consistent with the Commission's Product Environmental Footprint (PEF) method and relevant PEFCRs, and the detailed methodology arrives through delegated acts prepared with the Commission's Joint Research Centre (JRC).
The JRC published draft calculation rules for EV batteries first, with the draft delegated act put to public consultation on the Commission's Have Your Say portal in April 2024. The JRC's methodology report for industrial batteries followed in April 2025, with LMT rules to come after. Each category's methodology feeds its own delegated act, and each act restarts the "whichever is later" calculation for that category.
The delay is not a technicality for manufacturers. The methodology determines what primary data you must collect from your own plants and your cell and material suppliers, electricity sourcing rules, which processes need site-specific data rather than database averages, and how the supporting study must be documented for the public link the declaration requires. Data of that kind takes most of the 12 to 18 month lead time to assemble, which is why the regulation grants it.
The declaration is stage one of three under Article 7. Stage two is carbon footprint performance classes (Article 7(2)): batteries must carry a conspicuous, legible and indelible label stating the carbon footprint and the performance class of that model from that plant, comparable in spirit to an energy label. The same later-of mechanism applies: EV batteries from 18 August 2026, rechargeable industrial (except exclusively external storage) from 18 August 2027, LMT from 18 February 2030 and external-storage industrial from 18 February 2032, each date or 18 months after the relevant class delegated act and labelling-format implementing act enter into force, whichever is the latest. The Commission must review the classes every three years.
Stage three is a maximum life-cycle carbon footprint threshold (Article 7(3)): batteries whose declared value exceeds a ceiling set by delegated act cannot be placed on the EU market. Nominal application dates are 18 February 2028 for EV batteries, 18 February 2029 for rechargeable industrial (except external storage), 18 August 2031 for LMT and 18 August 2033 for external-storage industrial, again, each date or 18 months after the threshold delegated act enters into force, whichever is the latest. This is the step with commercial teeth: a declared number stops being disclosure and becomes a market-access condition. Since the thresholds will be informed by the declared values collected in stage one, the quality of early declarations matters beyond the paperwork.
From 18 February 2027, LMT batteries, industrial batteries over 2 kWh and EV batteries placed on the EU market must carry a battery passport under Article 77 of Regulation (EU) 2023/1542, an electronic record, accessible via a QR code, whose data content is set out in Annex XIII. Annex XIII includes the carbon footprint information from Article 7: the declared value and the breakdown behind it become part of the passport's data set, and the performance class joins it once Article 7(2) applies to the category.
So the two instruments run on separate clocks but converge: the declaration exists as a standalone document (accompanying the battery until it is QR-accessible under Article 13(6)), and the passport becomes its permanent home. A manufacturer building its passport data model now should treat the carbon footprint fields as structured, versioned data with the supporting study linked, not a PDF attached at the end, because the same values must stay consistent across the declaration, the label and the passport, and will be checked against the eventual threshold.
Note the passport's own dependencies are also in motion: the delegated act on passport data content and access rights is due by 18 August 2026 and had not been adopted as of July 2026. As with the carbon footprint acts, confirm the live state of the secondary legislation before treating any date as fixed.
The methodology acts are pending, but the shape of the obligation is settled in the regulation itself. What will not change: the declaration is per model per plant; the unit is kg CO2e per kWh of lifetime energy; the breakdown follows Annex II's life-cycle stages; the method will be PEF-based; and a public study must back the numbers.
That makes the preparatory work concrete regardless of the final act: map which of your products fall in which Article 7 category (the external-storage carve-out and the 2 kWh line decide real cases); identify the plants and supplier tiers whose primary data a PEF-based calculation will need, and start collecting it; and put the eventual values into a versioned record from the start, so the declaration, the label and the passport draw on one source rather than three copies.
And build the date-checking in. Every figure in this article that depends on a delegated act is current as of July 2026 and can change with a single Official Journal publication. Anchor your compliance calendar to the acts' entry into force, not to the nominal dates.
Not yet, as of July 2026. The nominal date was 18 February 2025, but Article 7(1) makes the obligation apply from that date or 12 months after the methodology delegated act and format implementing act enter into force, whichever is later, and those acts had not been adopted as of July 2026. Once they are, EV manufacturers have 12 months. Check the current status before planning against any date.
No. The declaration is a standalone Article 7 obligation that phases in per category on its own timetable; the battery passport is an Article 77 obligation applying from 18 February 2027 to LMT, industrial over 2 kWh and EV batteries. They connect: Annex XIII makes the declared carbon footprint part of the passport's data content, and until the declaration is accessible via the QR code it must physically accompany the battery.
Under Article 7(1): the manufacturer's administrative information, the battery model, the geographic location of the manufacturing plant, the carbon footprint in kg CO2e per kWh of lifetime energy, the same figure broken down by life-cycle stage, the EU declaration of conformity identification number, and a web link to a public version of the supporting study. It is drawn up per model per plant.
According to a methodology the Commission adopts by delegated act for each category, built on Annex II of the regulation and the Product Environmental Footprint (PEF) method, with detailed rules drafted by the Joint Research Centre. The EV draft was consulted on in 2024 and the JRC's industrial-battery methodology report was published in April 2025; the final acts define the data you must collect, so their adoption is the trigger to finalise your calculation approach.
No, the declaration is the first of three steps. Batteries will later need a label showing a carbon footprint performance class (nominally from 18 August 2026 for EV batteries), and later still the declared value must sit below a maximum threshold or the battery cannot be placed on the EU market (nominally from 18 February 2028 for EV batteries). Both steps use the same whichever-is-later mechanism, so their live dates also depend on when the underlying acts are adopted.
Rechargeable industrial batteries with exclusively external storage have the latest timetable: declaration nominally from 18 August 2030, performance classes from 18 February 2032 and thresholds from 18 August 2033, each subject to the whichever-is-later rule against acts the Commission is due to adopt from 18 February 2029 onwards. Industrial batteries over 2 kWh without that carve-out sit on the earlier 18 February 2026 nominal declaration date.
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