EU Issues Battery Carbon Footprint Delegated Act

On October 17, 2026, the European Commission published a delegated act on carbon footprint declarations under the Batteries and Waste Batteries Regulation. The act sets lifecycle carbon footprint calculation boundaries, data quality requirements and maximum emissions thresholds for energy storage systems and traction batteries. It will directly affect battery manufacturers’ compliance costs and require greater transparency in supply chain emissions data.

The calculation boundaries and data quality requirements matter together: manufacturers need to establish both which emissions fall within the assessment and whether the underlying data meets the required quality. A carbon footprint declaration therefore depends on more than a final emissions figure; it also depends on the information used to calculate that figure.

One of the first operational pressures could arise in collecting and checking supplier data. Manufacturers may need to review whether the emissions information they receive covers the relevant lifecycle boundaries and supports the required calculations. Suppliers, in turn, could face more detailed requests to explain how their figures were produced. The resulting workload will depend partly on how closely existing data practices align with the act’s requirements.

The maximum emissions thresholds create a further compliance consideration. Meeting data quality requirements and remaining within an emissions limit are distinct tasks: a well-supported calculation does not by itself establish that a battery meets the applicable threshold. If calculated emissions exceed that threshold, manufacturers may need to assess which contributing activities could be changed.

The immediate implication is greater demand for traceable emissions information across the battery supply chain. The scale of additional costs, and whether those costs affect purchasing decisions or product prices, will depend on implementation requirements, supplier readiness and the changes needed to meet the emissions limits. Further regulatory guidance and manufacturers’ disclosures will help clarify those effects.