Mandatory Carbon Footprint Reporting for Traction Batteries in China Takes Effect

On December 31, 2025, the General Office of the Ministry of Industry and Information Technology (MIIT) released the Notice on Carrying out Carbon Footprint Reporting for Automotive Traction Batteries (hereafter “the Notice”). The Notice mandates carbon footprint reporting for all automotive traction batteries with a rated energy exceeding 2 kilowatt-hours (kWh) sold in the Chinese market, effective immediately upon the Notice’s issuance. The pilot phase (from notice release to December 31, 2026) requires traction battery pack manufacturers to report carbon footprints for at least five typical models covering all chemical systems, supported by third-party verification reports. Beginning January 1, 2027, normalized management mandates carbon footprint accounting and third-party verification for all covered battery packs.

Obligated reporting entities encompass not only manufacturers and importers of traction batteries but also road vehicle producers who assemble their own batteries for use in vehicles. Companies must register on a designated information platform and follow a sequential submission process. This involves presenting data quality control measures, providing product activity data, performing a self-calculation using the platform’s background database, and ultimately uploading a final report that has been verified by an independent third-party institution.

Carbon footprint calculations must follow a full lifecycle methodology, where total emissions from material acquisition, production manufacturing, distribution and transportation, and recycling and reuse are divided by the battery’s total energy output over its service life. Cycle life must be determined through testing per GB/T 31484 Cycle life requirements and test methods for traction battery of electric vehicle (2015 version, including amendments), while green power certificates and regional grid factors may be applied for accuracy.

Meeting these requirements requires broad industry collaboration. Upstream suppliers provide necessary data, third-party bodies conduct verification, and research institutions support the background database development. The Notice also encourages enterprises to establish digital carbon management platforms and green supply chains, with plans to integrate carbon footprint results into automobile consumption policies, government procurement standards, and zero-carbon factory assessments, while aligning domestic rules with international systems.

Foreign stakeholders involved in producing or using traction batteries for the Chinese market should promptly begin compliance benchmarking to evaluate gaps between their current carbon footprint data and China’s calculation rules. This includes identifying key data deficiencies, establishing local data management capabilities and ensuring their supply chain, especially within China, can provide compliant and traceable carbon activity data.

Chinese sources of the article: https://www.gov.cn/zhengce/zhengceku/202512/content_7053525.htm

https://www.gov.cn/zhengce/202512/content_7053539.htm