Companies, NGOs and think tanks warn against potential shortcomings of EU carbon footprint rules for batteries

June 15, 2023

The group fear the EU's draft rules could perversely incentivise bigger, heavier vehicles with higher energy consumption.

Under the new EU Battery Regulation, battery manufacturers which want to sell in Europe will have to calculate and report their product’s entire carbon footprint, from mining to production to recycling. This data will then be used to establish different performance classes, and ultimately set a maximum CO2 limit for batteries coming into and produced in Europe. While the EU has made a clear commitment to green batteries, the devil remains in the detail of how the carbon emissions of batteries will be calculated. The work ongoing by the JRC and European Commission to prepare the upcoming delegated act on the methodology for calculation and verification of the battery carbon footprint is of vital importance and must ensure a reporting framework consistent with the objectives of the Battery Regulation and that does not incentivise greenwashing.

In a letter to EU lawmkaers, ECOS, DUH, IDDRI, Renault Group, The Shift Project, T&E and Verkor highlight two fundamental weaknesses in the latest JRC draft rules. Firstly, that the proposed Functional Unit that uses “energy provided over the service life” based on “battery durability” and “energy consumption of the vehicle” could perversely incentivise bigger, heavier vehicles with higher energy consumption, which will show a lower carbon footprint. Instead it is proposed that the service life be based on a fixed consumption for M1 vehicles and the absolute battery carbon footprint (not divided by a functional unit) should also be made available for each battery put on the market.

Secondly, the letter calls on the Commission to establish stricter rules around green energy claims, to ensure a stricter temporal and geographical link between green energy generation and use in battery manufacturing.

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