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 data field in the EU's Digital Product Passport framework wherever product rules require it. For batteries the declaration is set in law but not yet applicable, because the Commission acts it depends on have not been adopted.
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, excludes the use phase: its declarations cover raw material acquisition, production, distribution and end of life (Annex II).
Legal requirements: Battery Regulation
The Battery Regulation (EU 2023/1542) is the first EU law mandating product carbon footprint declarations, but the declarations are not yet applicable. Each depends on two Commission acts: a delegated act on the calculation and verification methodology, and an implementing act on the declaration format. Each declaration applies from the date below, or 12 months (EV batteries) or 18 months (other categories) after both acts have entered into force, whichever is later (Article 7). As of 11 October 2026 neither act has been adopted, and the Commission's batteries passport FAQ says this information "will not yet be required" in battery passports from February 2027.
| Earliest date | Obligation | Battery Type |
|---|---|---|
| 18 Feb 2025 | Carbon footprint declaration (not yet applicable) | EV batteries |
| 18 Feb 2026 | Carbon footprint declaration (not yet applicable) | Industrial rechargeable (>2 kWh), except exclusively external storage |
| 18 Aug 2028 | Carbon footprint declaration | LMT batteries |
| 18 Aug 2030 | Carbon footprint declaration | Industrial rechargeable (>2 kWh) with external storage |
| 18 Feb 2028 | Maximum carbon footprint threshold | EV batteries |
| 18 Feb 2029 | Maximum carbon footprint threshold | Industrial rechargeable (>2 kWh), except exclusively external storage |
| 18 Aug 2031 | Maximum carbon footprint threshold | LMT batteries |
| 18 Aug 2033 | Maximum carbon footprint threshold | Industrial rechargeable (>2 kWh) with external storage |
Each maximum threshold applies from the date shown or 18 months after the delegated act setting it enters into force, whichever is later.
Batteries will also be sorted into carbon footprint performance classes, with class A the best (lowest carbon footprint). The Commission sets the classes by delegated act, based on the distribution of batteries placed on the market in the previous three years, and the Regulation leaves the number of classes to that act (Annex II, point 8).
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
Under the ESPR, carbon footprint is one of the product parameters listed in Annex I. It becomes a DPP data field for a product group only where that group's delegated act requires it: Article 9(2) and Annex III leave the choice of DPP data to each delegated act. As delegated acts are adopted for textiles, steel, and other product categories, each will set whether and how carbon footprint information must be provided.
Related terms
- Digital Product Passport (DPP) — where carbon footprint data is disclosed
- ESPR — the regulation whose delegated acts can require 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