Carbon Footprint
Definition
A carbon footprint (in product regulation context: Product Carbon Footprint or PCF) is the total quantity of greenhouse gas (GHG) emissions — expressed in CO₂-equivalent (CO₂e) — attributable to a product across its full lifecycle: raw material extraction, manufacturing, transport, use, and end-of-life. Carbon footprint is a mandatory data field in the EU's Digital Product Passport framework and already legally required for batteries.
Lifecycle stages
A product carbon footprint typically covers:
| Stage | Examples | |-------|---------| | Raw material extraction | Mining, forestry, agriculture | | Manufacturing | Energy use, process emissions, waste | | Transport and distribution | Logistics between production stages | | Use phase | Energy consumption during product use | | End of life | Recycling, incineration, landfill |
Depending on the regulation and methodology, some stages may be excluded. The Battery Regulation, for example, focuses on manufacturing-phase emissions for initial declarations.
Legal requirements: Battery Regulation
The Battery Regulation (EU 2023/1542) is the first EU law mandating product carbon footprint declarations:
| Date | Obligation | Battery Type | |------|-----------|--------------| | 18 Feb 2025 | Carbon footprint declaration mandatory | EV batteries | | 18 Feb 2026 | Carbon footprint declaration mandatory | Industrial rechargeable (>2 kWh) | | 18 Aug 2028 | Carbon footprint declaration mandatory | LMT batteries | | ~2033 | Carbon footprint performance classes binding | EV and industrial batteries |
Batteries are classified into performance classes A to D based on carbon footprint, using a rolling three-year EU market average as the benchmark. Class A (lowest carbon) to Class D (highest allowed).
Methodology
The EU's preferred methodology for product carbon footprints is the Product Environmental Footprint (PEF) approach, aligned with ISO 14067 and EN 15804 (for construction products). These standards define:
- System boundaries (which lifecycle stages to include)
- Data quality requirements (primary vs. secondary data)
- Allocation methods (how to attribute shared emissions)
- Verification requirements
Important: The Battery Regulation PCF methodology differs from CBAM's embedded emissions methodology. Carbon footprint data from battery compliance cannot be directly used for CBAM declarations without conversion — the scopes and methodologies do not align.
ESPR and DPP
ESPR Annex III lists carbon footprint as a minimum DPP data field for products subject to delegated acts. As delegated acts are adopted for textiles, steel, and other product categories, specific PCF methodologies and performance thresholds will be set for each.
Related terms
- Digital Product Passport (DPP) — where carbon footprint data is disclosed
- ESPR — the regulation requiring carbon footprint in DPPs
- CBAM — the trade mechanism that prices carbon in imported goods
- CSRD — corporate reporting framework where product-level PCF feeds company-level GHG disclosures