Several challenges were highlighted and discussed during the workshop organised by WeLOOP and Renault at the LCM Conference, held in September 2023, focusing on the preparation of carbon footprint declarations for electric vehicle batteries based on the new European Battery Regulation.

Three key topics were discussed during this workshop: the functional unit (FU), data availability and its influence on results, and the application of the CFF, with a focus on recycling processes and recycled materials.

Here is a summary of the topics covered, complemented by some updates and recent advances in the environmental assessment of batteries.

Functional Unit (FU)

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The Battery Regulation defines the functional unit (Annex II) as “one kWh (kilowatt-hour) of total energy delivered by the battery system over its lifetime, measured in kWh. The total energy is obtained by multiplying the number of cycles by the amount of energy delivered during each cycle.”

During the workshop, Renault presented two different interpretations of this functional unit:

Based on these two sub-functional units, the climate change impacts of various battery sizes were calculated and compared to a third functional unit commonly used in the literature, which is based on the capacity of a battery pack in kWh. The results revealed that the proposed functional unit (standards, guidelines, and literature) could incentivise larger battery packs and high-consumption EVs.

The issue is that consumers might choose larger vehicles with bigger batteries, believing they are more environmentally friendly, even when they are unnecessary or unsuited to their actual needs.

Moreover, applying standards 1A or 1B presents challenges. On one hand, estimating the service life of EVs is difficult, and there are no standards for medium-duty batteries. On the other hand, cycle testing is time-consuming and expensive, and SOCE (State of Certified Energy)/SOH (State of Health) thresholds may overestimate the actual use of the battery.

Based on this observation, Renault proposed two additional functional units:

Note: The same proposals could be applied to M2, M3, N1, N2, N3, L6, and L7 vehicles, with specific (fixed) energy consumption values for each category.

During the workshop, it became clear that questions regarding the best choice of functional unit were valid, as opinions varied even within the battery community, making the topic a source of debate.

Many agree that the unit of measurement should be chosen based on the intended use of the carbon footprint declarations. If they are used to compare two batteries from different manufacturers, the cradle-to-grave capacity in kWh might be the most appropriate, whereas if they are intended to assess functionality, the kilometre seems more logical.

The battery's application appears to be particularly important in mobility use cases, unlike in stationary storage, where a capacity-based unit of measurement is less problematic.

Some opinions were even drastic, going as far as to question the introduction of a carbon footprint for the battery, arguing that it should instead be applied at the scale of the electric vehicle, with the battery's footprint included within the overall vehicle footprint.

From a more technical perspective, it was highlighted that it is currently not possible to accurately account for battery ageing due to its discharge phases. For now, it is therefore preferable to exclude battery usage from the functional unit.

The perfect functional unit may not yet exist, but in the future, it could lie in an advanced battery ageing model, incorporating both cycling and calendar ageing. In the meantime, to avoid a misleading functional unit that favours larger battery packs and, consequently, larger electric vehicles, it was requested that carbon footprint declarations also display the absolute carbon footprint values of the battery.

Availability of datasets and influence

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The document from the JRC clearly states that the soon-to-be-published delegated act will strongly encourage, or even require, companies to collect primary data for the most significant and relevant parts, primarily the manufacturing process and raw materials. Nevertheless, the use of secondary data will remain unavoidable, for instance, for auxiliary products.

However, it is known that for a single product, the impact differences between datasets from various databases can be significant. These differences are critical when it comes to classifying batteries and banning certain categories from the European market. To harmonise the carbon footprints of batteries, it would be essential for the European Commission to provide the necessary secondary data.

Indeed, to date, the EC has provided the EF 3.1 database for activities such as energy, transport, packaging, end-of-life, chemicals, metals and minerals, food/feed, and bio-based materials. However, this database is currently incomplete and does not allow for the proper modelling of batteries in accordance with the regulation. The EC is currently working on updating EF 3.1 to EF 4.0, for which 3,300 datasets covering all sectors will be created. WeLOOP contributed to the consultation for a revision of the dataset list to be developed as part of RECHARGE.

WeLOOP has acquired expertise in EoL recycling processes and has developed datasets for both conventional and innovative recycling processes and recycled materials. WeLOOP participates in research projects that propose innovative solutions for implementing eco-designed processes and developing inventories to create connections with industrial stakeholders. This led to the creation of the BATTERS platform, which provides a library of all available inventories to connect, for instance, OEMs seeking innovative processes. Datasets on recycled materials, battery manufacturing, and recycling processes are available upon request.

Finally, in response to the consultation on the revision of EF 3.1 datasets, the RECHARGE association sent a letter to the European Commission highlighting its members’ concerns, including the geographical and technological representativeness of datasets, the expiration dates of EF 3.1 datasets, the stability and maintenance of datasets when thresholds are implemented, potential updates to thresholds alongside dataset revisions, and other related issues.

Application of the CFF formula: recycling processes and recycled material

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The application of the CFF formula is a key factor in determining the carbon footprint of batteries. One of the primary challenges in the regulation is achieving a high level of recycled material integration and ensuring this is accurately reflected in carbon footprint declarations.

As part of the collaboration with Renault, WeLOOP modelled different battery recycling processes with various black mass (BM) compositions. It was found that variations in black mass could have a significant impact on a given process, raising concerns about the purity of black mass to minimise the environmental impact of these processes and the need to harmonise the available datasets.

This also raised the question of the functional unit for recycling processes. Recycling should be considered as a process for producing a recycled material, meaning the chosen functional unit should represent a quantity of recycled material of a specific quality, as not all processes yield the same quality of co-products.

To model these recycled materials, the impacts of recycling processes must be distributed among the different co-products. For this purpose, economic allocation appears to be the most plausible option. On this topic, the JRC document refers to the following rule: “Economic allocation is applied when the price difference between the various products exceeds a factor of four. A minimum of sixty months of global average prices (or revenues or costs) is used to evaluate price differences. All allocation factors, the approach used to calculate them, and the underlying data sources must be specified in the substantiating study of the CFP. If the process has been operational for less time, a shorter period (at least one year) can be used if duly justified in the substantiating study of the CFP. In such cases, the CFP must be updated no later than when five-year average values become available.”

However, in the current context, industrial-scale recycling processes are likely to have been operational for only a short time, and the economic value of by-products fluctuates significantly depending on the global geopolitical context. As a result, carbon footprint declarations will be heavily impacted.

Another important methodological challenge lies in the fact that secondary data for active materials also apply economic allocations to material extraction. As a result, secondary data will be tied to a specific economic allocation and timeline, while datasets on recycled materials will rely on different economic values from another timeline. The Commission should clarify this point or even provide economic data to be used for the allocation of co-products to recycling and recycled content. Given the significant rise in prices, what updates should be made to the declarations? And what thresholds need to be considered?

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A draft delegated act on the carbon methodology for electric vehicle batteries is expected to be published for consultation in early 2024. We hope that this document will provide answers to our questions.

Two PEFCRs for batteries are expected to be published in 2024 by RECHARGE and Environdec.

If you would like to learn more about the battery sector presented at LCM2023, please visit the LCM 2023 media library.

Thank you to all the participants of this workshop!

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