Carbon Footprint (Product)
A product carbon footprint is the total greenhouse gas emissions (expressed in CO2 equivalent) associated with a product across its entire lifecycle, from raw material extraction through manufacturing, use, and end-of-life. Under ESPR, carbon footprint is a mandatory DPP data field for batteries and is expected to be required for most other product categories.
Full Definition
Product carbon footprint is defined in ISO 14067 as "the sum of greenhouse gas emissions and removals in a product system, expressed as CO2 equivalent and based on a life cycle assessment." For ESPR DPP purposes, the carbon footprint must be calculated according to the methodology specified in the applicable delegated act — which for batteries is the EU Battery Regulation's carbon footprint calculation methodology, and for other products is expected to be the EU Product Environmental Footprint (PEF) methodology.
The carbon footprint must be expressed as CO2 equivalent per functional unit. For batteries, the functional unit is one kWh of energy storage capacity — so the carbon footprint is expressed as kg CO2e/kWh. For garments, the functional unit is one kilogram of garment or one garment unit. For electronics, the functional unit is one device.
The EU Battery Regulation sets carbon footprint performance classes for batteries — batteries are classified into classes A through E based on their carbon footprint per kWh. Batteries in the highest carbon footprint classes (D and E) will be prohibited from the EU market from a date to be specified by the Commission. This creates a direct commercial incentive for battery manufacturers to reduce their carbon footprint — not just to comply with disclosure requirements, but to avoid being excluded from the EU market.
Related Terms
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Register Your Digital Product Passport →Carbon Footprint Calculation for ESPR DPPs
The carbon footprint of a product is the total greenhouse gas emissions associated with the product across its lifecycle, expressed as kg CO₂ equivalent (CO₂e). The CO₂e metric converts all greenhouse gases (CO₂, methane, nitrous oxide, fluorinated gases) to a common unit using their global warming potential (GWP) over a 100-year time horizon. The ESPR carbon footprint calculation methodology for most product categories will be based on EN ISO 14067 (Carbon footprint of products — requirements and guidelines for quantification) and the EU's Product Environmental Footprint (PEF) methodology. The calculation must cover all lifecycle stages: raw material extraction (A1), transport to manufacturing (A2), manufacturing (A3), transport to use (A4), use phase (B6 for energy-using products), and end of life (C1–C4).
Carbon Footprint Verification Under ESPR
The ESPR delegated acts will specify verification requirements for carbon footprint claims. For high-impact product categories (batteries, steel, aluminium, electronics), third-party verification by an accredited auditor will be required. The auditor must verify that the carbon footprint calculation follows the methodology specified in the delegated act, that the activity data used in the calculation is accurate and complete, and that the calculation results are correctly reported in the DPP. Manufacturers should engage with accredited LCA consultants and verification bodies early in their ESPR compliance programme to understand the verification requirements and to build the data collection systems needed to support the verification process.
Carbon footprint calculation for ESPR DPPs must follow the methodology specified in the applicable delegated act. The EU Commission is developing a harmonised Product Environmental Footprint (PEF) methodology for carbon footprint calculation that will be used across ESPR product categories. The PEF methodology is based on the ISO 14040/14044 lifecycle assessment (LCA) standards but provides more specific guidance on system boundaries, allocation methods, and data quality requirements. Manufacturers that have already conducted LCA studies for their products using the ISO 14040/14044 methodology will need to review their LCA studies to ensure they are consistent with the PEF methodology before using the results in their ESPR DPPs. The EU Commission provides a free PEF calculation tool (the Environmental Footprint Calculator) that manufacturers can use to calculate product carbon footprints in accordance with the PEF methodology.