JBCE Feedback on the Draft Delegated Regulation supplementing the EU Batteries Regulation (EV Batteries)

On 28 May 2024, JBCE submitted its feedback on the draft delegated regulation supplementing the EU Batteries Regulation by establishing the calculation and verification of the carbon footprint of electric vehicle batteries.

In this paper, we highlight that:

• We are concerned that using the same number of cycles for Battery Electric Vehicles (BEVs) and non-externally chargeable Hybrid Electric Vehicles (HEVs) is not representative, nor technically justified, and would artificially create a major problem for mild/full HEV batteries.
• The scope of distribution (transport CO2) should only cover up until the battery assembly at the vehicle factory.
• The the cut-off rule should be defined based on both mass and energy use, not just mass.
• If the operators have already invested in green electricity and the certificates of their electricity contracts are clear, they should be allowed to use the CFP value in the certificates.

For more information, please contact info@jbce.org