Carbon footprint methodology for electric vehicle batteries

maki Consulting welcomes the publication of the draft Delegated Regulation establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. We believe the methodology and data basis should be as robust as possible, ensuring valid comparisons. It should moreover incentivise companies to achieve best-in class, improving their products, including at suppliers.

Congratulations on the publication of the carbon footprint methodology for EV batteries. In providing a standardised methodology, it avoids calculation variations between organisations and over time, supporting industry to decarbonise and enabling consumers to make informed purchasing decisions.

OG Clean Fuels applauds the European Commission's initiative to establish a methodology for calculating the carbon footprint of electric vehicle batteries. We believe transparent and harmonised information empowers consumers and businesses to make sustainable choices. We are also committed to advancing the adoption of clean and sustainable energy solutions.

UL Solutions welcomes the opportunity to give feedback on the draft delegated act laying down the methodology for calculating and verifying the life-cycle carbon footprint of electric vehicle batteries, as required by the EU Battery Regulation.

STX Commodities (STX) welcomes the introduction of the Product Carbon footprint (PCF) requirements for EV batteries to maximize the decarbonization potential of the battery value chain in the European Union and appreciates the opportunity to provide feedback on the methodology. Our comments refer mainly to the electricity modelling rules.

China Chamber of Commerce to the EU (CCCEU) represents more than 1.000 Chinese enterprises operating across europe. We welcome the opportunity to comment on the European Commissions public consultation regarding the carbon footprint methodology for EV batteries.

Regarding the document Annex-Ares (2024)3131389, Benchmark has the following feedback: Page Clause Comment 2 2.1. The definition of functional unit The total amount of energy provided by the battery over the batterys service life (Etotal), expressed in kWh does not match the definition mentioned in another EU battery JRC draft , Rules for the calculation of the Carbon Footprint of electric Vehicle Batteries…

Siemens AG is a technology company focused on industry, infrastructure and transport. We have a strong digitalisation expertise and long experience as providers of software solutions and manufacturers of highly complex electronics.

European Aluminium welcomes the publication of the draft Commission Delegated Regulation in its current version. European Aluminium in particular wishes to share its support for the choices made concerning the end-of-life modelling of EV batteries and their consistency with Recommendation 9332/2021, in particular related to the use of the Circular Footprint Formula, its parameters and default values.

RE-Source Platforms response relates to section 2.4 Electricity Modelling of the draft Delegated Act. Our main message is: Corporates active during all life cycle stages in scope of the Regulation must continue to be incentivised to sign renewable power purchase agreements (PPAs) in advancement of their climate neutrality goals. Their existing PPAs must also count towards their carbon footprint reduction.

The CEA supports the Commission’s approach of taking into account the carbon intensity of the country’s electricity mix, except in the specific case of direct connection of an active electricity generation asset to the battery production process.

Filed in French · English published by the European Commission

Northvolt welcomes the European Commissions carbon footprint methodology for batteries for electric vehicles in its current form, as a balanced compromise between different policy considerations. It is important and urgent to have a framework set in the immediate term, both for the sake of regulatory certainty for industry and for the sake of transparency on the carbon intensity of production to ensure a sustainable…

EUROBAT, the Association of Manufacturers of Automotive and Industrial Batteries, welcomes the upcoming ‎adoption of a methodology for determining the carbon footprint of electric vehicle batteries. EUROBAT maintains its ‎support for the introduction of a carbon footprint declaration, performance classes and maximum thresholds to ‎promote green batteries made in Europe.

Integrating the overall life cycle principle into electric batteries and their components is essential for controlling and monitoring the upstream production and downstream use of these devices. However, it is also important to include flexibility measures with regard to the supplychain that addresses the cycle of recycling and return to the supplychain circuit of the electric battery.

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CLEPA, the European Association of Automotive Suppliers, recommends alignment of the Delegated Regulation with the most relevant international standards to foster harmonization of reporting practices and their results and to promote the comparison of product carbon footprint on the base of analogues methodologies. Our main comments are: 1.

Integrating the overall life cycle principle into electric batteries and their components is essential for controlling and monitoring the upstream production and downstream use of these devices. However, it is also important to include flexibility measures with regard to the supplychain that addresses the cycle of recycling and return to the supplychain circuit of the electric battery.

Filed in French · English published by the European Commission

The International Council on Clean Transportation (ICCT) is pleased to respond to the public consultation on the Commission's proposal for a Delegated Regulation supplementing the EU Battery Regulation with a methodology for the calculation and verification of the carbon footprint of electric vehicle batteries.

Eurelectric response to the Public Consultation on the Draft Delegated Act establishing the methodology for the calculation and verification of the carbon footprint of EV Batteries. Eurelectric, representing the European electricity sector, welcomes the opportunity to comment on the draft delegated act establishing Product Carbon footprint (PCF) requirements for EV batteries.

Note: Any views expressed are the views of the German Environment Agency and may not in any circumstances be regarded as stating an official position of the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection or the Federal Republic of Germany.

We welcome the definition of a methodology for the calculation of the carbon footprint of a battery that takes into account the country specific electricity mix, although we would have preferred the production mix rather than the residual consumption mix.

From the perspective of LCA modellers, ifeu welcomes the Commissions draft act on the methodology for calculating the carbon footprint of electric vehicle batteries. Especially prioritising direct connection to renewable energy and opting for a battery approach for the functional unit.

Jaguar Land Rover Automotive PLC (JLR) is a British company with global capabilities. JLR has manufacturing facilities in the UK, China, Brazil and Slovakia, a contract manufacturing site in Austria and a vehicle assembly site in India.

Bosch welcomes the publication of the draft delegated act establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. We believe the methodology should be as robust and as harmonised with existing standards as possible.

DUH welcomes the Commissions draft act on the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. The most energy- and carbon-intensive part of battery manufacturing is the production chain of battery cells, responsible for as much as 75% of energy consumption.

The purpose of promoting sustainability via harmonised carbon footprint declarations based on a life cycle perspective and the life cycle assessment (LCA) methodology is an initiative we encourage. However, it requires a lot from the design of the calculation methodology to be practically feasible for the practitioners.

AVERE, the European Association for Electromobility, is pleased to provide its response to the public consultation on the Batteries Regulation Delegated Act concerning the Carbon Footprint methodology. Representing a diverse coalition of stakeholders from across the electromobility sector, AVERE is committed to advancing sustainable transportation solutions that balance environmental responsibility with industry…

The Nickel Institute as association the nickel industry takes note of the Annex to the Commission Delegated Regulation supplementing Regulation (EU) 2023/1542 of the European Parliament and of the Council by establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries as published in May 2024.

Contemporary Amperex Technology Thuringia GmbH - CATT welcomes the proposal on the carbon footprint methodology for electric vehicle batteries and appreciates the opportunity to provide feedback on the draft of the Delegated Act supplementing Regulation 2023/1542, which entered into force last July.

The Advanced Propulsion Centre UK (APC) collaborates with UK government, the automotive industry and academia to accelerate the industrialisation of technologies, supporting the automotive sector transition to net-zero. This methodology for the calculation and verification of applying a carbon footprint to electric vehicle batteries is welcomed.

Tokai COBEX welcomes the current text. Overall we consider it adequately addresses the challenges of calculating the battery carbon footprint to promote low-carbon batteries in the EU market. Specifically, the following points are appropriate: i. the mandatory company-specific for modelling the production of anode active material, ii. the location-based modelling of electricity at a national scale, iii.

ecoinvent welcomes the proposal on the carbon footprint methodology for electric vehicle batteries and appreciates the possibility of providing feedback on the draft of the Delegated Act supplementing Regulation 2023/1542, which the European Commission adopted on July 12, 2023.

ECOS welcomes the draft Delegated Act on a methodology for calculating the carbon footprint of electric vehicle batteries. ECOS considers the methodology an integral part of further reducing vehicle and battery-related emissions and we are pleased to see it has been delivered swiftly.

EASE Feedback on Joint Research Centers (JRC) Carbon Footprint Methodology and Declaration for EV Batteries EASE welcomes the development in formation of the methodology and declaration for Carbon Fooptrint of EV Batteries.

The Belgian, federal Environmental product policy unit of the Federal Public Service (FPS) Health, Food Chain Safety and Environment does not support the proposed PEF methodology. The attached comments specifically focus on the proposed modelling of the energy mix.

The automotive industry takes note of the recently published delegated act establishing the methodology for the calculation of the carbon footprint of electric vehicle batteries, as mandated by Article 7 of the Batteries Regulation.

RECHARGE welcomes the long awaited draft delegated act establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. For the sake of business planning and for the environment, RECHARGE believes it is vital to have a robust and resilient framework in place. The draft is a simplified take on the JRC final draft which is somewhat easier for industry.

The Global Battery Alliance wishes to provide feedback on sections 2.2.3, 2.3.6, 2.4, 2.5 & 2.6 of the draft Delegated Act. The GBA requests that the EU facilitate harmonisation of requirements across its legislation and globally by applying the cut-off rule of the EU PEF Method (3%) to the methodology for EV batteries without changes.

Concerns about Inconsistencies in the Delegated Act on Calculating the Carbon Footprint of Batteries The draft text for the delegated act on calculating the carbon footprint of batteries contains some inconsistencies concerning electricity modelling.

Our feedbacks to current delegated act on carbon footprint calculation are as the following: 1. The national grid consumption mix in electricity modelling does not reflect the fact that for large countries like China and US, the grid mix can be quite different in sub-regions. Therefore, the act shall add sub-national grid consumption mix in the eletricity modelling part. 2.

ACEM, the European Association of Motorcycle Manufacturers, welcomes the publication of the draft Commission Delegated Regulation and the possibility to provide feedback through Have your say portal. ACEM regrets that the methodology reported in the draft Regulation is different than the one reported by JRC publication of June 2023 (JRC: Rules for the calculation of the Carbon Footprint of Electric Vehicle…

Developments in the EU Batteries Regulation, which can have a negative impact on the EU’s energy single market principle and also on Europe’s competitiveness with regard to battery investments. The new draft legislation contains significant inconsistencies with regard to electricity modelling (paragraph 2.4). It requires actors in the battery value chain to use a national average energy mix.

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1. Comment on 2.1, (b): - FEqC per year proposed 3 typical numbers, however, it is difficult to accept as they are without any justification. 2. Comment on 2.2.1, (b), (i): - Transport operations of the final ... products to the site where they are used is covered by 2.2.1, (c) 3.

Feedback to the Commission draft delegated Regulation supplementing Regulation (EU) 2023/1542 on estimating lifetime carbon footprint of batteries for EVs. Clear rules for estimating and communicating the lifecycle carbon intensity of batteries are necessary to allow companies to communicate their sustainability efforts and climate impact transparently, reliably and uniformly in the single market.

Ministry of Economy, Trade and Industry of Japan is concerned that the declared value of the carbon footprint is not properly assessed since the differences in electricity supply according to the function of electric vehicle batteries are not taken into account, and expects the EU to establish a system that properly reflects the decarbonization efforts of companies.

The Government of the Republic of Korea submits comments on the European Commission's proposal for a delegated regulation supplementing Regulation (EU) 2023/1542 by establishing the methodology for calculating and verifying the carbon footprint of electric vehicle batteries.

EBRA is the European organisation defending the interests of professional companies involved with the collection, sortation, treatment, material recovery and repurposing or reusing of portable, industrial and EV batteries. We do not include the activities of lead-acid battery operators.

Samsung SDI is grateful to the EU Commission for providing an opportunity to submit feedbacks on the delegated regulation that establishes a methodology for calculating and verifying carbon footprints for electric vehicle batteries that supplements the European Parliament and Council Regulations (EU) 2023/1542 of the European Commission.

As a cross-sector association with member companies operating in different industries and at different stages of the supply chain (electronics, chemicals, polymers, automotive, HVACR, machinery, semiconductors, wholesale trade, precision instruments, pharmaceuticals, steel, non-ferrous metals, textiles, ceramics and glass products), JBCE welcomes the opportunity to contribute to the draft delegated regulation1 act…

The German Association of the Automotive Industry (VDA) unites more than 650 manufacturers and suppliers under one roof. Its members develop and produce cars and trucks, software, trailers, bodies, buses, parts and accessories, and ever new mobility offerings. We represent the interests of the automotive industry and stand for modern, future-oriented multimodal mobility on the way to climate neutrality.

While companies around the world already investing in green energies, this new act using national average electricity consumption mix as standard will not realise intended benefits, therefore future green power energy investments will slow down.

The BMW Group welcomes the Delegated Act on the Methodology for the Calculation and Verification of the Carbon Footprint of Electric Vehicle Batteries, although we have certain concerns with the current state of the draft. In the proposed delegated act for EU battery regulation, the EU no longer plans to accept renewable energy certificates.

[Functional unit calculation] We would like to point out and argue that unique/appropriate set of default values are to be set/defined for distinctive and wider range of electrified vehicle types such as HEVs and PHEVs, especially in consideration and observation of the bill proposal that gives details only presumed for BEVs.

1. For 2.4, it is unreasonable to only recognize directly connected electricity and the national average electricity consumption. For example, the Critical Raw Materials Act refers to recommendation C(2021) 9332 and suggests using different electricity models to calculate environmental impacts.

Battery Association for Supply Chain (BASC) would like to submit the following four comments to the draft. 1. Clarification of the CFP calculation method In order to reduce the burden on operators for CFP calculation and the preparation of a study report, the implementation items for compliance with the regulations should be clarified and simplified.

We fully understand the EU's concerns about the carbon footprint of electric vehicles and we are very pleased to see that the European Commission has timely released this carbon footprint methodology to promote low-carbon and sustainable development of EV batteries. After reading this methodology in detail, we noticed several points of concern that may warrant further discussion and improvement.

Response to the Public Consultation of the Delegated Act establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries BASF welcomes the introduction of the Product Carbon footprint (PCF) requirements for EV batteries to maximize the decarbonization potential of the battery value chain in Europe.

2.1.(c).: Suggestion: The actual application scenario (vehicle model) shall prevail if the actual application scenarios can be distinguished. 2.2.1: Suggestion: 1. Complete the description or issue a special PCR. 2. Manufacturers cannot collect the data after the battery delivery, back-end data is held by dealers or OEMs. It is recommended that the distribution phase not be included in the lifecycle. 3.

We appreciate the opportunity to provide feedback on the European Commissions draft delegated act concerning the methodology for calculating the carbon footprint of batteries. As representatives of the Economic Chamber of Non-Ferrous Metals and Recycling, we play a pivotal role in advocating for sustainable practices within our industry.

Our comments relate uniquely to Section 2.4 - Electricity Modelling of the Annex to the delegated act. We recognise that the use of contractual instruments (CIs), without solid guardrails to ensure robust zero emissions claims and avoid double counting, would weaken the battery carbon footprint regulation and that using national averages does hedge against certain risks.

EDF welcomes the proposal for the Batteries and Waste Batteries Delegated Regulation dedicated to establishing the methodology for the calculation and verification of carbon footprint of EV batteries. The Batteries and Waste Batteries Regulation is a major initiative to create a competitive and sustainable value chain for batteries in Europe in line with the new EU Industrial Strategy and Circular Economy Action…

The European graphite association welcomes the introduction by the Commission of a new carbon footprint methodology for battery-grade graphite. The current proposal is fully in line with the Batteries regulation and will help further a greater decarbonisation of the automotive and energy storage sectors.

Please find attached our fully contribution. Here is an overview : IMT (Institut Mobilités en Transition) & IDDRI (Institut du développement durable et des relations internationales) welcomes the recently proposed methodology from the Commission.

While Lubrizol commends the European Commission for its efforts to establish a single, standardised methodology for assessing the environmental footprint of batteries through the Product Environmental Footprint (PEF) methodology, we would like to highlight three areas of concern: 1. The Circular Footprint Formula relies on complex end-of-life predictions; 2.

Regarding (5): In Europe, claims about renewable energy (RE) use must be proven with Guarantees of Origin (GOs) (RED Art. 19). The use of Energy Attribute Certificates (EACs) from other countries that are equivalent to the European GOs should be allowed if relevant legislation mandates and actively ensures these as a unique instrument for tracking.

CONTRIBUTION FOR DELEGATED ACT ON BATTERIES CARBON FOOTPRINT Rules for electricity modelling 24/05/2024 Contributors: Caroline Mir, Pierre Sacher ADEME The delegated acts purpose, amongst others, is to provide the best information to the consumers and to foster low carbon European battery production.

The buy-side of electricity cannot agree the draft electricity modelling method described in section 2.4 (at Page 17 of Annex - Ares(2024)3131389 English (703.9 KB - PDF - 33 pages)). We would like to give our opinion and request. Considering the fact that there is few success case even in Europe, where electricity can be fully supplied from isolated renewable energy sources disconnected with the electricity grid.

The Bavarian Center for Battery Technology at the University of Bayreuth, Germany, welcomes the proposal for the carbon footprint methodology for electric vehicle batteries. The proposed annex contains detailed instructions for calculating the product environmental footprint of batteries placed on the market, including all life cycle phases except the use phase, as instructed in the Battery Regulation (EU)…

For over 75 years, the Schaeffler Group, as a leading global automotive and industrial supplier, has been driving pioneering inventions and developments in the areas of motion and mobility. With innovative technologies, products, and services in the fields of CO2-efficient drives, electromobility, Industry 4.0, digitalization, and renewable energies, Schaeffler is a reliable partner for making motion and mobility…

As one of worlds largest automotive companies who have pioneered the development of electrified vehicles, Toyota welcomes the opportunity to feedback on various items we find critical to address in the "Batteries for electric vehicles - carbon footprint methodology".

The EU Commission considers batteries to be a strategic part of Europe's clean and digital transition and a key enabling technology, particularly regarding the automotive sector. It is therefore the aim of the EU Commission to develop Europe in a highly competitive global race as a pioneer in the sustainable production and use of batteries.

The Commission's decision to deviate from product environment footprint (PEF) methodology on the use of energy attribute certificates in the draft delegated act, is based on a lack of trust in notified bodies and will have a general negative impact on the PEF methodology also in other markets.

8. For Article 2.4, it is recommended that the electricity modelling should add the way of recognizing the national renewable energy-green electricity certificate and the national/regional grid carbon footprint factor. Article 2.4&2.4.1 refers to The carbon footprint of the consumption of electricity shall be that of the national average electricity consumption mix.

4. For Article 2.2.1 (d) End-of-life and recycling, subpoint (b) battery dismantling and the dismantling of battery and its components in the last subparagraph, please explain the difference between battery dismantling in these two phrases and which part of the dismantling is part of the life cycle and is required to calculate the carbon footprint impact.

1. For Article 2.1 (b), it is recommended to clarify the basis for the typical number of full equivalent charge-discharge cycles per year in the Etotal calculation formula. Otherwise, the industry or national standards of the battery manufacturer's location should be acknowledged or measurement standards should be provided, allowing the manufacturer to calculate and provide data that aligns with the actual…

Thank you for the opportunity to comment on the draft. On behalf of the members of EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufactures, we would like to comment on the proposal regarding the 1% cut-off criterion per system component for the assessment of the Carbon Footprint.

Comments: o The definition section needs to be improved by providing more precise and succinct definitions. o Avoid imposing excessive requirements. While conforming to ISO 9000, ISO 14000, and EMAS standards for data collection is beneficial, mandating third-party certification increases costs for companies. Section 2.3.1.

In response to the proposal published by the European Commission, JAPIA (Japan Automotive Parts Industries Association) agrees with the basic idea from the viewpoint of "reducing carbon dioxide emissions" and "promoting resource recycling." It was also confirmed that a number of verifications have been carried out by the European Commission and the Joint Research Centre.

1. It is sopken in the regulation draft that company specific data of suppliers are required to be shared in aggregated form with NB granted to access. Will NB participate in such earlier stage or only in the final verification stage? What if the suppliers promised to meet the regulation requirements but fail in the end? Such situation will extremely negatively affect a battery business. 2.

1. More detailed guidance is required on how to determine the compliance of the Company-specific dataset provided by the supplier with the ILCD data format. Are the dataset export from Simapro, Gabi and OpenLCA in ILCD database format automatically considered as compliant with the ILCD data format?

2.2.1. (b) In Annex II of Regulation (EU) 2023/1542, Main product production life cycle stage doesnt include battery cells and battery components such as anode/cathode active material production, anode and cathode production, and electrolyte production. On the other hand, Main product production life cycle stage, in this Delegated Act draft, includes them. 2.2.1.

2.2.1 (a) Raw material acquisition and pre processing How does waste management in different production stages fulfill the relevant DQR requirement? Will the waste management treatment's carbon footprint of raw material acquisition and pre-processing be considered under non-mandatory most relevant process DQR requirements?

We support the move to using full equivalent charge-discharge cycles per year (FEqC per year) and vehicle warranty, as this both simplifies the calculation and ensures a fair comparability between batteries. Further, the revised calculation removes unintended consequences such as rewarding inefficient vehicles with a lower carbon footprint.

While the commercial warranty may provide a general idea of a battery expected Lifespan, we Argue that it does not have an accurate measure for the years of operation (YoP), as detailed in Chapter 2.1. The battery technical features, such as energy density, power, charge rate, and sliding rate, can have a greater impact on its Lifespan.

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T&E welcomes the Commissions draft act on the methodology for calculating the carbon footprint of electric vehicle batteries. Prioritising direct connection to renewable energy, thus rewarding clean manufacturing, and opting for a battery approach for the functional unit are key principles and should be kept.

The requirement of the draft text to use of the national average energy mix to calculate the battery carbon footprint undercuts the value proposition of EU battery material producers starting from the first step in the value chain: mining.

Yesterday, as a battery recycler, we will source green electricity from a PV system that we do not operate ourselves. Therefore, in our opinion, the purchase of electricity from other renewable sources should also be taken into account in the CO2 footprint calculation. Only the energy mix of the country is not incentivising green electricity initiatives with other partners. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

Phillips 66 Limited welcomes the opportunity to respond to the Batteries for electric vehicles carbon footprint methodology. Phillips 66 is a global energy company, based in the US. Phillips 66 Limiteds Humber Refinery, in the UK, is the only European producer of graphite coke, an essential component of the anode in lithium-ion batteries for electric vehicles and the largest mineral component of the battery.

I am Chase Nachtmann, Battery Systems Engineer for Zero Motorcycles, the market leader in electric motorcycles. The proposed metric for evaluating the carbon footprint for electric vehicle batteries will penalize vehicles that are more energy efficient which use a smaller battery pack to travel the same distance as a less efficient vehicle.

9.The EU considers that in many jurisdictions outside of it, it is currently impossible to ensure that a green certificate contractual instrument is the only proof of the environmental attributes of the electricity, which poses the risk of insufficient evidence of environmental claims. The use of contractual instruments is therefore not permitted. How should Chinese manufacturers respond to this claim?

1.How can information security be ensured when the transport process exposes supply chain maps? 2.In the calculation of total energy, the number of annual cycles is uniformly stipulated as 60, and the given value is not in line with the actual situation.

My most important recommendation that will significantly streamline this process, minimise error, and maximise correct submissions is to provide an additional supplementary document that: i. Flow charts for how to follow and instructions on ILCD guidelines, nodes, PEF compliance, LCDN, carbon feedstocks, compatible software, what notified bodies, etc.

The electricity modelling in section 2.4 of the draft Annex with the CFP method shows inconsistencies with far-stretched consequences for the EU energy market. It undermines established policy-embedded energy origin tracking policies in Europe.

INEOS Automotive welcomes the publication of a methodology to evaluate the carbon footprint of batteries which can enable customers and businesses to compare different products in an effective way. After detailed review, we would like to highlight three main areas of concern in the proposed methodology: (1) Its applicability to different vehicle technologies, (2) that this proposed model favours vehicles with larger…

1. For 2.1 (i), how to determine the "energy capacity" when calculating "Etotal"? It is suggested to replace "energy capacity" with "rated capacity. 2. For 2.2.1 (b) (i), what does "transport operations of the final ... products to the site where they are used." mean? Is it "the point of placing the battery on the market"? If yes, then this equals to "2.2.1 (c) Distribution". 3.

The draft text for the delegated act on calculating the carbon footprint of batteries requires the use of the national average energy mix. This is not in line with the Product Environmental Footprint method, which the Battery Regulation referred to, and deviates from several European legislation. Further it contains in itself an inconsistency with regards to electricity modelling.

1. In point 2 of subparagraph (j) of clause 3.1.2 of the draft delegated act, it is required that the public version of the carbon footprint study report, when disclosing the information modelled in the viewpoints, state which dataset or datasets were used for averaging the electricity mix based on the dataset listed in point (m), if applicable, but the draft does not have point (m), so it is suggested to add a note…

Dear reader, I'd like to share 2 thoughts after an enjoyable reading of this instructive methodology proposal: 1. It would be great if one section can be added further explain the scope of application (though it's still understandable) "battery" whether it means cell or module or pack?

If fossil fuels are consumed in the manufacturing process of the electric car battery, it would be fair to pay CO2 allowances for the consumed CO2 in the country where the battery is imported, as this would incentivise foreign producers to reduce fossil fuel consumption.

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Hi, I have some doubts about "2.6. Recycled content and end of life modelling". First, what is the difference between Rreturn and Rcoll in equation (4)？ Second, Whether "CFF" method has overlapping accounting with" the carbon footprint of raw material acquisition and pre-processing "?