Carbon footprint is a mandatory field in most DPP frameworks — and it is one of the most technically demanding to get right. This article walks you through the methodology, scope, and verification requirements for DPP carbon footprint declarations.
Calculation Methodology
For batteries, the mandatory methodology is the EU Battery Regulation Delegated Regulation on Carbon Footprint (expected adoption 2025). It will specify use of ISO 14067:2018 (Carbon footprint of products) and align with the Product Environmental Footprint (PEF) Category Rules for batteries.
For other ESPR sectors, the Commission's Product Environmental Footprint (PEF) methodology (Commission Recommendation 2013/179/EU) will typically be specified in the delegated act.
Lifecycle Stages (System Boundary)
- A1–A3: Raw material extraction and processing + manufacturing — typically 60–80% of total footprint for batteries
- A4: Transport to customer
- B1–B7: Use phase — electricity for charging, operational emissions
- C1–C4: End-of-life — collection, transport, recycling, landfill
- D: Beyond system boundary — recycling credits (reported separately)
Data Quality Requirements
The regulation distinguishes between primary data (actual measured data from your specific supply chain) and secondary data (industry average emission factors from databases like ecoinvent, GaBi, or the EU's EF-database). For carbon footprint classes and maximum thresholds, primary data for key hotspot processes will be required.
Third-Party Verification
For batteries entering the EU market from 2026, carbon footprint declarations must be verified by an accredited third-party verifier (under EN ISO/IEC 17029). The verifier reviews the calculation methodology, data sources, system boundary, and allocation methods. The verification statement must be referenced in the DPP.
Carbon Footprint Performance Classes (Batteries)
The Battery Regulation introduces A–E performance classes for carbon footprint intensity (kg CO₂e per kWh of rated energy). Class A = best performers in the EU market. Products in class E face restricted market access from the threshold date. D-Pass automatically calculates the performance class based on your declared values and the Commission's thresholds.
Practical Steps
- Commission a Life Cycle Assessment (LCA) study from an accredited consultant using the relevant methodology
- Collect primary data from your top 3–5 emission hotspot processes
- Use secondary data (ecoinvent 3.x) for remaining processes
- Document all assumptions, allocation methods, and data sources in a Product Carbon Footprint Report
- Submit to a verification body for independent review
- Upload the verified value and verification statement reference to your DPP on D-Pass