---
title: Carbon footprint and recycled content, ahead of time
deck: Neither the carbon footprint declaration nor recycled-content quotas apply yet, but both need evidence that takes years to build. What's coming, and how to start the trail now.
description: The EU battery carbon footprint declaration and recycled-content quotas: what applies when, the method, and the evidence to start collecting now.
category: Regulation
date: '2026-10-31'
image: /assets/tiles/a-0-1.jpg
order: 10
---

Two of the regulation's biggest demands, the carbon footprint declaration (Art. 7) and minimum recycled content (Art. 8), aren't in force yet. Both wait on Commission acts, and the recycled-content quotas start in 2031. It is tempting to leave them. That would be a mistake, because both rest on supplier data per model and per plant, and that data takes longer to gather than the acts take to arrive.

## Carbon footprint

**When.** The declaration applies to EV batteries, industrial batteries above 2 kWh and LMT batteries, but only 12 or 18 months after the Commission adopts the methodology and format acts. As of October 2026 neither had been adopted, so the duty hasn't started; Commission guidance in 2026 said the declaration shouldn't be shown in passports from February 2027. For LMT batteries the earliest date is 18 August 2028.

**What follows.** After the declaration come performance classes (Art. 7(2)), with A the best, shown on the battery's label, and then a maximum threshold (Art. 7(3)): batteries above it can't be placed on the market. For EV batteries the threshold applies from February 2028 at the earliest.

**The method.** The rules build on the Product Environmental Footprint category rules for rechargeable batteries:

- **Functional unit**: one kWh of total energy delivered over the battery's service life, reported as kg CO₂e per kWh.
- **Stages**: raw material acquisition and pre-processing, main production, distribution, and end of life and recycling. The use phase is excluded, and results are reported per stage.
- **Per model, per plant**: one declaration for each battery model at each manufacturing plant, with the plant named.
- **Primary data**: battery-specific materials need plant-specific data, not database averages. Secondary data from databases such as ecoinvent fills the remaining gaps.
- **Offsets don't count.** They can be stated separately, but not subtracted.

Figures for EV batteries commonly fall around 50 to 150 kg CO₂e per kWh, driven mostly by where the cells are made and the electricity used.

**Start now:** collect energy use, material inputs, process emissions and transport for your own operations, and ask cathode, anode, electrolyte and cell suppliers for their site energy mix and process emissions. Document each source and how good it is, and leave label space for the class.

## Recycled content

**Documentation.** Recycled cobalt, lithium, nickel and lead have to be documented per battery model, per year and per plant, from 18 August 2028 or 24 months after the delegated act, whichever is later. The act was due in August 2026 and hasn't been adopted. Expect to declare recycled content in the passport from the start.

**Minimum shares** for industrial batteries above 2 kWh, EV batteries and starter batteries (Art. 8(2) and (3)):

| From | Cobalt | Lead | Lithium | Nickel |
|---|---|---|---|---|
| 18 August 2031 | 16% | 85% | 6% | 6% |
| 18 August 2036 | 26% | 85% | 12% | 15% |

LMT batteries come in later. For cobalt, lithium and nickel the share is measured within the active materials; for lead, within the whole battery.

**Open questions.** The calculation method, verification and format are left to the delegated act, so there is no official template yet and no settled answer on mass balance versus physical segregation.

**Start now:** write into supply contracts running past 2031 that suppliers give recycled-content figures per material, per model, per year and per plant, keep records for ten years, give you audit rights, and agree what happens if a figure turns out wrong.

## Why it's one trail

Carbon and recycled content draw on the same suppliers, the same per-plant granularity and the same need to show where each number came from. Build one evidence trail for both: every figure with its source, date and approver, kept per model and plant, ready for a notified body to check.

## FAQ

### Is the battery carbon footprint declaration required in 2027?

Not as of October 2026. It applies only after the Commission adopts the methodology and format acts, and its guidance said the declaration isn't to be shown in passports from February 2027.

### What are the recycled content targets for batteries?

From 18 August 2031: 16% cobalt, 85% lead, 6% lithium and 6% nickel. From 18 August 2036: 26% cobalt, 85% lead, 12% lithium and 15% nickel.

### Can carbon offsets reduce a battery's declared footprint?

No. Offsets may be stated separately but can't be subtracted from the declared figure.

## Sources

- [Carbon footprint in the battery passport](https://dpphero.com/en/blog/carbon-footprint-battery-passport), DPP Hero
- [Recycled content in the battery passport](https://dpphero.com/en/blog/recycled-content-battery-passport), DPP Hero
- [EUBR compliance checklist](https://kezzler.com/eubr-compliance-checklist/), Kezzler