The Delegated Act on the Carbon Footprint of EV Batteries: What the Industry Should Expect and Why Simplification Is the Only Viable Path Forward
The European Commission is currently working on one of the most technically demanding regulatory elements of the new Batteries Regulation: the Delegated Act defining the methodology for calculating and verifying the carbon footprint of electric vehicle batteries.
For this analysis, we reviewed all 127 responses submitted by companies, industry associations, NGOs and public bodies. The conclusion is clear. The industry supports the overarching goals of the regulation, but the methodological approach proposed in the draft risks failing when confronted with real-world supply chains and practical feasibility limits.
1. An ambitious intention
The draft Delegated Act follows a clear objective: transparent and comparable carbon footprints across the entire lifecycle of batteries. The methodology is designed to adhere strictly to the EU Product Environmental Footprint (PEF) approach and to be scientifically rigorous and harmonised.
However, the feedback tells a different story. The level of complexity is extremely high, and paradoxically this complexity does not ensure that the reported carbon footprint values will achieve the expected accuracy.
Many companies, especially SMEs, highlight the following points:
The methodology requires highly granular process and material data.
At the same time, secondary data must be used in many instances because primary data is not available.
These secondary datasets are rarely specific enough to represent the actual CO₂ footprint of the battery.
This leads to a fundamental paradox. The calculation becomes maximally complex, yet the result quality remains uncertain. Even more clearly: a highly detailed calculation based on insufficient input data cannot deliver values that reflect the true carbon footprint.
More detail does not automatically mean more accuracy.
2. An unsolvable challenge for European battery pack producers
A central concern expressed across many submissions is the situation of European battery pack producers. They have virtually no possibility of obtaining real primary data from cell manufacturers unless it is provided voluntarily.
Why?
Individual cells are not yet covered by the battery passport requirement.
Without this requirement, there is no regulatory basis for requesting data.
Many Asian manufacturers treat process data, material compositions and LCI-relevant primary information as confidential intellectual property.
Even when data exists, it is often not provided in a form that complies with EU-compatible LCA methodologies.
As a consequence, the responsibility for the carbon footprint is transferred to the European economic operator, but this operator cannot source the required data. battery pack producers are therefore forced to rely on secondary datasets, regardless of whether these reflect the true footprint of the supplied cells.
The regulation demands accuracy, but in practice does not create the conditions needed to achieve it.
3. Industry calls for less complexity and more robust standardisation
Across the 127 responses, three trends clearly emerge:
Unified and verified standard datasets are considered essential.
A Carbon Footprint Data Stock, a central EU database with standardised LCI values, is widely requested.
The industry wants a simpler, more robust and internationally workable methodology.
A contradiction appears frequently. On one side, companies want to differentiate through green PPAs, innovative production methods or higher recycling content. On the other side, they call for a less granular methodology, which would inherently limit the opportunities for differentiation.
This conflict remains unresolved and will determine whether the Delegated Act becomes a driver of innovation or of bureaucracy.
4. A realistic view: most emissions originate in the material chain
Several manufacturers highlight that 70–80 percent of the carbon footprint originates from:
raw material extraction
refining
material preprocessing
The influence of European OEMs or battery pack producers, for example through green electricity or process efficiency, is limited.
This leads to an important insight. An excessively granular methodology does not automatically produce more accurate results. It primarily increases administrative burden without significantly improving footprint accuracy.
Standardised datasets for the material chain are therefore not a simplification for convenience, but a necessary foundation for producing reliable results.
5. China and the global market: transparency versus protection of intellectual property
Chinese manufacturers and associations express strong reservations. Their main points:
Disclosure of granular production data is not acceptable.
The detailed PEF requirements would expose critical process IP.
Exporting to the EU would become substantially more difficult if complete primary data disclosure became mandatory.
6. Our assessment: the Delegated Act will need to be significantly simplified
After reviewing all feedback, our view is clear. The final methodology will need to be more pragmatic, more standardised and less granular. Otherwise, it will not work in practice.
The reasons are evident:
SMEs cannot handle the current complexity.
Global supply chains cannot deliver the required primary data.
The accuracy of many calculation steps is not guaranteed despite the complexity.
The major CO₂ reduction levers lie in areas that are better regulated through standardised values.
Interoperable digital data flows require clear, streamlined interfaces.
The direction is correct, but the methodological framework must be sharpened significantly.
7. What companies should do now
Regardless of the final version of the Delegated Act, companies should take action now:
Build digital data models and workflows that integrate the battery passport and carbon footprint calculation.
Collect and structure material and process data where available.
Use interface-ready solutions that can process both primary and secondary data efficiently.
Prepare for standardised EU data pools, which are highly likely to become central to the system.
Companies that begin now will not only be compliant by 2027, they will also be more transparent, efficient and competitive.