Automotive and battery manufacturing coalition signs joint letter of concern on Carbon Footprint Rules for Electric Vehicle Batteries

10 Sep 2023
The EU JRC (Joint Research Centre) has recently issued a final draft of the “Rules for the calculation of the Carbon Footprint of Electric Vehicle Batteries (CFB-EV)”, entering a phase of consultation. Battery and automotive manufacturing organisations, including CLEPA, have jointly addressed representatives from the European Commission (DG GROW and DG ENV) with a letter of concern regarding these Rules. 

“While the effort to regulate and provide additional guidance on the carbon footprint calculation of electric vehicle (EV) batteries is both sensible and appreciated, the draft contains some aspects that raise concerns for the industry, particularly regarding the assessment of the impact of recycled material (and the so-called modelling of the “end-of-life”)”, they write. 

The JRC document proposes to apply the so-called Circular Footprint Formula (CFF) to the calculation of battery carbon footprint, in reference to the Product Environmental Footprint (PEF) method, as a way to model the end-of-life of EV batteries. The coalition raises that this calculation not only adds a significant complexity burden for practitioners and reporting companies, but also deviates from other globally recognised accounting practices. Therefore, they recommend EU institutions to use the widely adopted and recognised “cut-off” approach for the modelling of end-of-life of EV batteries, instead of the CFF. 


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