Insights 2023.12.29

Impact brought about by the EU Battery Regulation ③ ~Process up to market launch and conformity assessment~

table of contents

Taku Nozoko , Zeroboard Business Development Headquarters Automotive Team
Yoshiki Okada, Automotive Team , Zeroboard Business Development Division

In November 2023, Impact Report 2 on the EU Battery Regulation summarized the necessary items for calculating carbon footprints (CFP) required by the EU Battery Regulation, the supply chain (SC) data collaboration required for this purpose, and the supply chain data sharing platform such as Ouranos Ecosystem that serves as a Contents for this. This time, we will focus on the process leading up to market launch under the EU Battery Regulation, and will also delve into the reports that must be disclosed, third-party verification of those reports, and patterns of CFP data collaboration between suppliers and OEMs to meet verification requirements.

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The process to market based on the EU Battery Regulation

In the previous column, we pointed out that in order to comply with the EU Battery Regulation coming into force in February 2025, it will be necessary to compile performance requirements for storage batteries and calculate CFP. This chapter explains the process of reporting the compiled attribute information on storage batteries, undergoing inspection, and launching the target storage batteries on the European market. Since the report format and the need for conformity assessment (third-party verification) vary depending on the type of storage battery and its production format (continuous production or limited production), this time we will explain the launch process for continuously produced storage batteries that are installed in electrified vehicles, including EVs and PHVs.

The following is a detailed process outline for the process from compiling battery attribute information to launching the battery on the market. ZB has identified the process based on the requirements of Articles 4 and 6 of the original EU Battery Regulation*1 and on interviews with third-party verification organizations.

Conduct product testing, WLTP testing, etc., and evaluate the battery performance of electric vehicles. Compile the evaluation results into test reports and manage them.
Create of technical documentation, quality system documentation, and CFP research documentation
・Create of technical documents including Manufacturing drawings, standards information, specifications, and other technical requirements for storage batteries
・Create quality system documents that include governance regarding product quality and product test results regarding quality, etc.
・Create of CFP study documents that describe the CFP calculation results, DQR scores, cutoffs, and other calculation requirements for storage batteries
Request an evaluation from a Notified Body (conformity assessment body) ・Select one Notified Body for the target storage battery and request an evaluation to see if the various documents comply with the requirements of the EU Battery Regulation.
Confirmation of evaluation results by the Notified Body ・The Notified Body will carry out a conformity assessment and issue a Statement (a statement regarding the evaluation results)
Create an EU Declaration of Conformity and declare the essential requirements with full responsibility. Create an EU Declaration of Conformity based on the statement issued by the Notified Body.
- Information about the Notified Body that carried out the evaluation and information to identify the target battery are included in the EU Declaration of Conformity
Affixing the CE marking ・CE stands for "Conformité Européenne (English: European Conformity)" ・The CE marking is affixed to the battery to indicate that the battery complies with EU Battery Regulation. For specific Contents about the CE marking, please refer to the Japan External Trade Organization (JETRO) website *2 and the Ministry of Economy, Trade and Industry website *3
The CE marking must be affixed conspicuously, clearly and permanently to the battery, or, if this is not possible or justified due to the nature of the battery, it may be affixed to the battery's packaging and accompanying documentation.
・Install the attached storage battery in an electric vehicle
Launched on the European market: Launched electric vehicles equipped with storage batteries that comply with EU Battery Regulation on the European market

When the CFP calculation requirements under the EU Battery Regulation come into effect on February 18, 2025, Manufacturing of battery packs or Manufacturing and sellers of electric vehicles will be required to complete all of the above processes before placing electric vehicles on the European market. Assuming it takes two months to transport the vehicle to Europe, one to two weeks to affix the CE marking and install the battery, and about two months from evaluation by the Notified Body to the issuance of a Statement, it appears that step ②, "Create of technical documentation, quality system documentation, and CFP research documentation," itself will need to be completed between August and September 2024.

( Create by our company based on the text of the EU Battery Regulation *1 and interviews with battery supply chain operators)

About Notified Bodies: Conformity Assessment Bodies for EU Battery Regulation

Just to reiterate, a Notified Body is a third-party verification organization that carries out conformity assessments with the EU Battery Regulation. Notifying authorities are established under the domestic laws of the governments of member states of the European Commission. Existing verification organizations apply to the Notifying Authority, which then evaluates their suitability. As a result of the evaluation, the third-party verification organization that receives a notification is certified as a Notified Body, and can thereafter conduct conformity assessments of storage battery manufacturers with the EU Battery Regulation. Notifying authorities not only evaluate and notify Notified Bodies, but also conduct audits.

( Create by our company based on the EU Battery Regulation text *1 )

Basically, third-party verification organizations with head offices or branches in member states of the European Commission are eligible. Representative organizations that may be certified as Notified Bodies in the future include TUV SUD in Germany, Socotec in France, DNV in Norway, and SGS in Switzerland. There is also BSI in the UK, although it is not a member state of the European Commission. All of the above third-party verification organizations have branches in Japan.

Documents required for conformity assessment of the EU Battery Regulation

According to the original text of the EU Battery Regulation*1 , "Annex VIII, Module D1 '5. Quality System'," businesses that Manufacturing and sell storage batteries on the European market must apply to a Notified Body for a conformity assessment of the storage batteries EU Battery Regulation. When applying, the following information and documents must be prepared. As mentioned in point ② of the process leading up to market launch, this includes technical documentation, quality system documentation, and CFP research documentation.

( Create by our company based on the EU Battery Regulation text *1 )

While specific items that must be included in technical documentation and quality system documentation have been specified, the details of what should be included in CFP research documentation have not yet been decided, and it will be necessary to wait for the Delegated Act on CFP calculation methods, which is scheduled to be adopted by February 2024. Since the final draft *5 published by the European Joint Research Centre, which was introduced in the previous column, proposes what should be included in CFP research documentation, this column will also refer to this document. Details of each document are provided below.

[About technical documentation]

Technical documentation is Create to demonstrate the compliance of the target storage battery with the applicable requirements set out in Articles 6 to 10 and Articles 12, 13, and 14 of the original text of the EU Battery Regulation *1 . To enable Notified Bodies and regulatory authorities to assess compliance, the technical documentation must include environmental information and evidence relating to the design, Manufacturing, and operation of the storage battery, such as specifications, planning, CFP, and recycling rate. Information to be disclosed based on the above applicable requirements includes restrictions on the content of hazardous substances such as mercury and cadmium (Article 6), calculation of carbon footprint (Article 7), use of recycled materials (Article 8), evaluation of battery performance and durability (Articles 9 and 10), and evaluation of the battery's expected lifespan (Article 14).

( Create by our company based on the EU Battery Regulation text *1 )

[About quality system documentation]

The quality system documentation must describe the internal programs and plans, management manuals and procedures, and test records for controlling the quality of the batteries in question, to ensure that the batteries comply with the applicable requirements of the EU Battery Regulation as described in the technical documentation.

( Create by our company based on the EU Battery Regulation text *1 )

[CFP Research Document]

According to Annex II Carbon footprint of the original text of the EU Battery Regulation*1 , it is clearly stated that the carbon footprint calculation and verification methods required by Article 7 must comply with the Product Environmental Footprint Category Regulations (PEFCRs) for batteries. At present, the CFP calculation standard that may be subject to compliance as PEFCRs is expected to be the Final Draft issued by the European Joint Research Centre (commonly known as the JRC Report). The JRC Report requires the preparation of two reports: a public CFP Supporting Study Report to publicly disclose whether the CFP calculation results for the target storage battery comply with the guidelines, and a private CFP Supporting Study Report to be Create by Notified Bodies for verification and conformity assessment.

The information contained in the "Public CFP Supporting Study Report" is as per the document below. Article 7 of the original text of the EU Battery Regulation*1 clearly states that "a web link providing access to the public version of the research document supporting the carbon footprint value" must be prepared. Therefore, this document must be uploaded to the website of the declaring company.

(Create by our company based on the JRC report *4 )

The "Confidential CFP Supporting Study Report" to be submitted to Notified Bodies is as follows. In order for Notified Bodies to evaluate whether or not they comply with the calculation requirements in the JRC report, this document must clearly state the calculation logic for each calculation item that is the details of the CFP, as well as the sources and evidence of activity data and Emission intensity data.

(Create by our company based on the JRC report *4 )

Cooperation of CFP-related information between suppliers and manufacturers for the Create of CFP research documents

As explained in the previous column, according to the JRC report, in calculating the CFP of storage batteries, calculations must be made using primary data based on the Manufacturing site for the composition amount of each raw material and the Energy consumption during Manufacturing for cells, positive electrode materials, negative electrode materials, electrolyte, positive electrode active material, negative electrode active material, etc. In other words, storage battery Manufacturing, who are the declaring business operators, must share emission amount information on a part-by-part basis with suppliers such as battery cell manufacturers and electrode manufacturers.

( Create by our company based on the JRC report *4 and the Ministry of Industry , Trade and Industry's carbon footprint data on storage batteries*5)

Furthermore, as explained in the previous chapter, in the "confidential CFP supporting study report" that must be Create for Notified Body conformity assessment, suppliers are required to provide information on the composition of raw materials for cells and electrodes, which are highly confidential from a business perspective, as well as information on the consumption of utilities such as electricity and water by product. Since the information that requires collaboration is complicated, it will be organized as follows, starting from the purpose of collaboration.

Purpose of collaboration	Information that suppliers should share	Those who need to view the information on the left
For the declared business (battery manufacturer) to calculate CFP	-CFP data for entire parts (by life cycle stage) ・DQR value*	・Declaration business operator (storage battery manufacturer) ・Notified body
For Notified Bodies to assess whether the CFP of the target storage battery is calculated in compliance with the requirements	- CFP details for parts (calculation logic for each item, activity amount, Emission factor, DQR value, etc.) ・Cutoff criteria, evidence information for each data, etc.	・Notified body

(JRC Report＊4(Create by our company based on

Based on the above, there is some information, such as the CFP details of parts, that does not necessarily need to go through the declaring business (battery manufacturer). Therefore, the JRC report proposes the following three options for data sharing between suppliers, manufacturers, and notified bodies:

Option No.	overview	Player-specific collaboration data
Option 1	The declaring business receives all data and submits it to the Notified Body	•Suppliers submit all data to the declaring company • The declaring entity manages all data and submits the data required for conformity assessment to the Notified Body
Option 2	Each business submits the data necessary for evaluation to the Notified Body	•Suppliers submit CFP values to the declaration company • The declaring entity ensures that the necessary data for conformity assessment is submitted to the Notified Body. •It is expected that each business will directly submit the data required for evaluation to the Notified Body.
Option 3	An entrusted third party (such as a data management Company or consulting Company) receives all data and submits it to the Notified Body	• The declaring business will request a third party to receive, manage, and submit all data to a conformity assessment body •Suppliers submit all data to third parties •The third party manages all data and submits the data required for conformity assessment to the Notified Body.

(Create by our company based on the JRC report *4 )

Details are provided below.

[Option 1] The declaring business receives all data and submits it to the Notified Body

The supplier provides all information to the declaring entity, which then compiles the information, Create a "public CFP supporting study report" and a "private CFP supporting study report," and submits them to the Notified Body. The advantage of this option is that it is very efficient, since the process from conformity assessment request to assessment is carried out between the declaring entity and the Notified Body. On the other hand, the disadvantage is that it is necessary for the supplier to provide all highly confidential information to the declaring entity, which may cause discord in the business.

(Create by our company based on the JRC report *4 )

[Option 2] Each business submits the data required for evaluation to the Notified Body

Suppliers share only the information necessary for the Declaring Business to calculate their own CFP, such as the total CFP value of the parts, and the Declaring Business compiles this information and Create a "Public CFP Supporting Study Report." With regard to the items to be shared with the Notified Body in the "Confidential CFP Supporting Study Report," each business compiles information related to the partial requirements necessary for the CFP conformity assessment of their own parts, and communicates and cooperates with the Notified Body on their own. The advantage of this approach is that security is guaranteed, as information that is highly confidential from a supplier's perspective does not go through the Declaring Business. On the other hand, the disadvantage is that both the supplier and the Declaring Business will have to communicate with the Notified Body separately.

(Create by our company based on the JRC report *4 )[Option 3] An entrusted third party receives all data and submits it to the Notified Body

The declaring business entrusts the compilation of CFP-related information to a third-party data management business. The supplier and the declaring business provide all information to the third-party data management business under a confidentiality agreement, which then compiles the information, Create a "public CFP supporting study report" and a "private CFP supporting study report," and submits them to the Notified Body. The advantage of this option is that it is efficient, since the process from conformity assessment request to assessment is carried out between the data management business and the Notified Body business. In addition, security is guaranteed, since information that is highly confidential from the supplier's business perspective does not go through the declaring business. On the other hand, the disadvantage is that costs are incurred in commissioning a third-party data management business.

(Create by our company based on the JRC report*4)

As for the development policy for the Ouranos Ecosystem, Option 2 is expected, since the Alpha version of the Guidelines for Data Linkage Mechanisms in the Supply Chain *6 clearly states that suppliers must share CFP certificates with downstream businesses as verification results from third-party verification organizations. In any case, manufacturers and suppliers will need to carefully discuss which option to go with in order to comply with the EU Battery Regulation.

Conclusion

This time, we focused on the process up to market launch based on the EU Battery Regulation , and explained the reports that must be disclosed, third-party verification of the reports, and the patterns of CFP data sharing between suppliers and OEMs to meet the verification requirements. In particular, we provided details on the Create required for the CFP data of storage batteries to be prepared for compliance assessment with the EU Battery Regulation, and the options for sharing related information between suppliers and manufacturers.

The next installment will be a series on the impact of EU Battery Regulation, including trends among the European Commission and European OEMs. In addition, we plan to hold a webinar in February 2024 on trends in the European automotive supply chain, including responses to battery regulations, with the European research team from our business partner, Bank of Tokyo-Mitsubishi UFJ, taking the stage.

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<Source>
* EU Battery Regulation(Official Journal of the European Union) 2023/7/28
*2 Japan External Trade Organization (JETRO) Practical Guidebook for CE Marking Conformity Measures for Self-Declaration (EU)
*3 Ministry of Economy, Trade and Industry, Appendix 4, Supplementary Reading, CE Marking Technical Documentation Create Guide
*4 Joint Research Centre （JRC）Rules for the calculation of the Carbon Footprint of Electric Vehicle Batteries (CFBEV)
*5 Ministry of Industry , Trade and Industry , April 21, 2023, METI Battery Carbon Footprint Document
*6 Ministry of Industry, Trade and Industry, Digital Architecture Design Center (DADC) Alpha version of guidelines for data sharing mechanisms in the supply chain (related to storage battery CFP and DD)

Article author

Taku Nozoko (General Manager of the Solutions Development Department, Sales Division)
After working in business and IT consulting Service at MUFG Bank, Ltd. Research and Consulting Company , he participated in the launch of Zeroboard in 2021. While working, he enrolled in the Graduate School of Environment and Information Studies at Yokohama National University to study and research LCA environmental assessment methods. With a background in environmental information studies, he is in charge of business development and as a consultant at Zeroboard , managing the demonstration project for the "CFP Guidelines" by the Ministry of Economy, Trade and Industry and the Ministry of the Environment, and leading the development project for the Ouranos Ecosystem's app requirements (CFP calculation and collaboration) in collaboration with DADC and ABtC. Most recently, he has been providing consulting Service related to CFP and DD compliance support and CBAM compliance under EU Battery Regulation . He has experience calculating CFP for over 50 products (20 of which are related to automobiles and automobile parts).