Starting in 2027, every EV and industrial battery sold in the EU needs a "digital passport" showing its
carbon footprint. By 2028, batteries exceeding a to-be-determined limit won't be allowed on the EU market, even with a valid passport. On paper, this looks like a wall built to keep high-carbon Chinese batteries out.
A closer look shows something different:
1. The calculation rulebook isn't even finished.
The full timeline — declaration starting 2025, a hard cap by 2028 — was already decided in 2023. But the methodology — how
carbon footprint gets calculated for EV batteries — is still being finalized, over two years behind schedule. Industrial batteries are further along — actively enforced since Feb 2026, not just written into law.
2. Academic research can't even agree on who's ahead.
One peer-reviewed study puts China's battery carbon footprint at 104 kgCO2eq/kWh, with Korea ranked 3rd (behind the EU, US). Another puts Korea at 141 vs. China's 124.5 — the opposite order. Same topic, contradicting conclusions.
3. So the smarter move is company- and plant-level data — not country rankings.
If researchers can't agree nationally, "which country is cleaner" is the wrong bet. What matters is your own plant's verified number.
4. The one real apples-to-apples test we have? A virtual tie.
CATL, Samsung SDI, and SK On all run plants in Hungary — same grid, similar NMC811 chemistry. One study measured CATL at 10.95 kgCO2eq/kWh, Samsung SDI at 9.92 — a ~9% gap within normal estimation uncertainty, not a decisive win. SK On was in the same study without a comparable published figure — a data gap worth noting.
5. China isn't standing still.
Leading Chinese battery makers are scaling low-carbon production lines, switching to renewable-powered manufacturing and optimizing process emissions at a rapid pace. Framing the EU rule as a one-sided blow to China misses how fast the entire global industry is adapting to decarbonization standards.
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