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.
EPH
EVE POWER HUNGARY KFT. Kft.
Company · Hungary
3
positions filed
in the 326 files tracked
1
legislative file
of 326 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
EVE POWER HUNGARY KFT. Kft. filed 3 positions on 27 May 2024, across 1 of the 326 legislative files tracked here, attaching a full position paper 3 times.
What they argued
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…
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