Insights 2024.05.23

Interpretation of the CFP detailed rules of the EU Battery Regulation ①

table of contents

Taku Nozoko, Director, Solutions Development Department, Sales Division , Zeroboard Inc.

In three columns, we shared the impact of the EU Battery Regulation*1 on businesses in the automotive and battery Industry from October 2023 to January 2024. In this article, we will introduce the functional units of the CFP, the component items specified as Mandatory Company Specific processes (processes that require calculations using primary data), and how data should be shared across the supply chain, based on the publication of the draft CFP detailed rules (CFP detailed rules) of the EU Battery Regulation Regulation on April 30, 2024.

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1. Position of the CFP Bylaws

The detailed rules published on April 30, 2024 consist of two documents: "The Methodology for the Calculation and Verification of the Carbon Footprint of Electric Vehicle Batteries" *2 (tentatively referred to as "CFP Calculation and Verification Detailed Rules"), which presents the methodology for calculating and verifying the carbon footprint of onboard batteries, and "The Format of the Carbon Footprint Declaration for Batteries" *3 (tentatively referred to as "CFP Declaration Detailed Rules"), which stipulates the declaration Status for disclosing the carbon footprint. Both are drafts and are currently open for public comment, soliciting opinions from stakeholders.
These detailed rules complement Article 7 of the EU Battery Regulation, "Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries." The detailed rules for CFP calculation and verification refer to "the delegated act or of the implementing act" in Article 7 of the regulation, "the delegated act or of the implementing act, respectively, referred to in the fourth subparagraph, points (a) and (b), whichever is the latest, for electric vehicle batteries," and are limited to "batteries installed in electric vehicles." On the other hand, the detailed rules for CFP declaration refer to "the implementing act" in Article 7 of the regulation, "a carbon footprint declaration shall be drawn up for each battery model per manufacturing plant, in accordance with the implementing act referred to in the fourth subparagraph and containing," and are applicable to all batteries subject to CFP calculation and declaration.

The structure of both detailed regulations is as shown in the diagram below, consisting of two parts: a regulatory document summarizing the relationship with the existing EU Battery Regulation as a delegated regulation and legal elements, and an Annex summarizing the calculation and disclosure requirements for battery manufacturers. The detailed regulations for CFP calculation and verification are based on the European Commission's recommendation document for environmental footprint calculation, "On the use of the Environmental Footprint methods to measure and communicate the life cycle environmental performance of products and organizations" *4 , and the draft Contents inherits the Contents of the JRC report *5 Create by the European Joint Research Centre. In addition, the management format for CFP data in actual calculation work is specified to comply with the "ILCD Data Format" *6 , and the naming convention for CFP data identifiers (UUIDs) is specified to comply with the "ILCD Naming Handbook" *7 .

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Below is a summary of the column, which you can download.

2. Future schedule

This chapter explains ZB's view on the schedule from the effective date to application of the "Detailed Rules for CFP Calculation and Verification" and the "Detailed Rules for CFP Declaration" published on April 30, 2024. Both are "Delegated Acts" and the latter are classified as "Implementing Acts." Based on the legislative process of each and the items stated in the main body of the EU Battery Regulation, we have estimated the start date of application by accumulating the necessary period.

3. CFP functional units

Generally, the unit for calculating and disclosing CFP must be Settings in "functional units." The "functional unit" must be defined as an index that quantifies the performance of the product being calculated based on its non-compliant functions. This article introduces the functional unit for batteries installed in electric vehicles and its calculation method. It then explains our view on the impact of this calculation method on EVs, HVs, and PHVs.

4. Manufacturing processes/suppliers covered by the accounting

This article explains the changes in the Manufacturing process subject to calculation presented in the "Rules for the calculation of the Carbon Footprint of Electric Vehicle Batteries" (hereinafter referred to as the JRC report) developed by the European Joint Research Centre, i.e., the changes from the suppliers with which the report is conducted. Compared to the JRC report, the scope has been narrowed and the definition has been made more specific.

5. Cooperation policy within the supply chain

This section explains the policy for sharing information on CFP or its breakdown between suppliers and manufacturers. Although there are no major changes to the form of collaboration itself from the JRC report, the description has been made more specific.

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＜Reference source＞

*1: EU Battery Regulation(Official Journal of the European Union) 2023/7/28
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1542
*2: Detailed rules for CFP calculation and verification (draft)
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13877-Batteries-for-electric-vehicles-carbon-footprint-methodology_en
*3: Detailed rules for the CFP declaration format (draft)
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13878-Batteries-format-of-carbon-footprint-declaration_en
*4: Recommendation document for calculating environmental footprint
https://eur-lex.europa.eu/eli/reco/2021/2279/oj
*5: JRC Report
https://eplca.jrc.ec.europa.eu/permalink/battery/GRB-CBF_CarbonFootprintRules-EV_June_2023.pdf
*6: ILCD data format
https://eplca.jrc.ec.europa.eu/LCDN/developerILCDDataFormat.html
*7: ILCD Naming Handbook
https://eplca.jrc.ec.europa.eu/uploads/ILCD-Data-Network-of-UUID-and-versionnumber-of-datasets.pdf

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).