Dr Mohammad Ali Rajaeifar and Daniel Philipp Mueller, TÜV SÜD, have co-authored a paper with Professor Oliver Heidrich from Newcastle University which discusses the delay in the Delegated Act for CF declaration of EV batteries and its impact on industry and research stakeholders.

The EU Battery Regulation (2023/1542) establishes a comprehensive legal framework to ensure that batteries placed on the EU market are sustainable, safe, and recyclable, with far-reaching implications for global battery industries, research communities, and supply chains. Among its key provisions, Article 7 introduces mandatory carbon footprint (CF) reporting for certain battery types, beginning with electric vehicle (EV) batteries.

The requirements will be implemented through Delegated Acts specifying calculation methodologies and verification procedures. However, the Delegated Act for CF declaration of EV batteries, intended for adoption by February 2025, remains in draft form which has disrupted supply chain planning, research activities, and investment decisions across the EV battery sector. Original Equipment Manufacturers (OEMs) and carbon footprint practitioners are reluctant to commit resources to methodologies that may change, given the draft’s unresolved technical ambiguities. These include unclear system boundaries, inconsistent approaches to data ownership, availability and quality, and insufficiently defined audit and verification requirements. The lack of precision leads to divergent interpretations among suppliers, causing misalignment and contractual hesitations within the value chain.

For the research community, the absence of finalised rules undermines the ability to align studies on battery sustainability with regulatory expectations. Without a harmonised, science-based CF methodology, assessments risk being speculative or incompatible with future legal requirements. This uncertainty is compounded by the expectation that similar Delegated Acts will be developed for other battery categories; unresolved methodological issues in the EV battery framework are therefore likely to propagate to other segments of the market.

Third-party verifiers and prospective Notified Bodies (NOBOs) face parallel challenges. Verification programs for Article 7 require detailed components, yet the draft Delegated Act offers only high-level guidance. This forces repeated program revisions, increasing costs, delaying readiness, and risking inconsistent verification approaches across the market, which may compromise comparability and fair competition.

The current situation conflicts with the objectives of the EU Green Deal and the EU Battery Regulation itself, both of which depend on timely, transparent, and reliable CF rules to support decarbonisation and resource efficiency. Swift adoption of clear and stable methodological rules is urgently needed to provide regulatory certainty, enable market readiness, and maintain Europe’s competitive position in the sustainable battery market. Addressing the methodological ambiguities in the draft Delegated Act would equip OEMs, researchers, and verification bodies with the necessary clarity to align innovation, investment, and compliance efforts—thereby advancing the Regulation’s goals of fostering sustainable mobility and reducing the adverse impacts of batteries on ecosystems.

Reference

Rajaeifar, M.A., Müller, D.P., Hanton, M. et al. The EU battery carbon footprint rules need urgent attention. Nat Energy (2025). https://doi.org/10.1038/s41560-025-01844-3

Press release with thanks from TÜV SÜD.