Position Paper
31 July 2024

Carbon Footprint of Industrial Batteries

This position makes several recommendations to improve the Joint Research Centre’s 2nd draft methodology to calculate and verify the carbon footprint of industrial batteries.

Critically, EUROBAT calls on the Commission to base the calculation of the functional unit of off-the-shelf batteries on the durability and performance parameters referred to in Art. 10 of the Batteries Regulation. For custom-made batteries that value should be based on a Technical Purchasing Specification (TPS) including the requested application life. Overall, the value for the life expectancy of the battery in the carbon footprint formula must be based on the battery’s technical specifications. The commercial warranty is no good proxy for a battery’s service life.