[Regulatory Update] EU Battery Regulation phases in carbon-footprint disclosure for EV batteries — calculation and classification rules become a precondition for application

The EU Battery Regulation (Regulation (EU) 2023/1542) introduces a system requiring EV batteries, certain industrial batteries and LMT batteries to calculate and declare their carbon footprint at the level of the manufacturing plant and battery model. The calculation covers the lifecycle stages of raw materials, manufacturing, distribution and end-of-life treatment, and conformity with the calculation methodology must be demonstrated through technical documentation. For EV batteries, the requirement for a carbon-footprint performance class has 18 August 2026 set as one reference date, but the actual application date is whichever is later when compared with 18 months after the entry into force of the relevant delegated or implementing acts. A simple statement such as "third-party verification becomes mandatory across the board from the end of 2026" should therefore be avoided.