Article 7 of Regulation (EU) 2023/1542 and Annex II introduce a staged carbon-footprint regime: declaration, then performance class, then binding maximum thresholds. The regime is narrow in scope — it never applies to portable batteries — yet it generates more supplier questionnaires than almost any other article. This paper fixes the scope, the staged deadlines and the voluntary product-carbon-footprint (PCF) opportunity for nickel-metal hydride (NiMH) makers.
Article 7 applies only to rechargeable LMT and EV batteries, rechargeable industrial batteries above 2 kWh and SLI batteries. It unfolds in three stages: a carbon-footprint declaration stating kg CO₂e per kWh over the lifecycle, calculated under a Commission methodology and verified by a notified body; a performance class label (A/B/C-style) once delegated acts define the bands; and eventually maximum threshold compliance. Deadlines are staggered by category: EV batteries began declarations in February 2025, industrial batteries above 2 kWh follow from February 2026, and LMT batteries from August 2028, with class labels and thresholds arriving roughly 12–18 months after each methodology act.
Annex II and Article 7(1) list the covered categories exhaustively; portable batteries — sealed cells and packs at or below 5 kg that are neither LMT, SLI, EV nor industrial — are absent from the list and therefore carry no carbon-footprint declaration, class or threshold obligation, regardless of chemistry. The scope map below illustrates the point: the in-scope count for portable is zero. A 2,400 mAh AA NiMH cell, a 4.8 V medical pack and a 9 V block need no notified-body carbon file. Large NiMH industrial strings above 2 kWh do enter the regime — and at 1.2 V per cell that requires a pack of roughly 1,667 Ah or more, uncommon outside stationary storage and traction.
Where it applies, the Annex II declaration must cover raw-material acquisition and pre-processing (including nickel, rare-earth and steel supply for NiMH), main-product production, distribution, end-of-life and the credits from recycling, following defined system boundaries, allocation rules and data-quality requirements. It must use primary activity data for the manufacturer's own processes and specified secondary data for upstream stages, carry uncertainty statements and be third-party verified. Crucially, the carbon footprint is expressed per kWh of energy delivered, so cycle life enters the denominator — a long-life NiMH industrial pack spreads its footprint over more delivered energy, a structural advantage worth quantifying.
Out of legal scope does not mean out of customer scope. European OEMs building their own organisational carbon footprints (CSRD reporting, ISO 14067 product claims, green-public-procurement scoring) increasingly request carbon data from every supplier. A voluntary NiMH PCF — built on the same lifecycle structure, using electricity-mix data for manufacturing sites and supplier data for nickel and alloy — answers those questionnaires without notified-body cost. It also supports comparative marketing: aqueous NiMH chemistry avoids the energy-intensive organic solvent recovery and dry-room infrastructure of lithium cell production, and mature hydrometallurgical nickel recycling closes the loop.
A pragmatic NiMH carbon program: first, classify each product and document why portable items are out of Article 7 scope; second, for any pack above 2 kWh, engage a notified body early because methodology acts and verification slots have long lead times; third, collect site-level electricity and gas data and supplier-specific nickel/alloy data to replace conservative defaults; fourth, publish a voluntary PCF summary for portable lines aligned to ISO 14067 structure; and fifth, re-run the study annually because the grid mix and recycled content change the result. Keep assumptions explicit — an illustrative or preliminary PCF must be labeled as such.
Weijiang Power classifies every NiMH product against Article 7 in writing, supports large industrial packs above 2 kWh with notified-body-ready lifecycle data, and offers voluntary ISO 14067-structured PCF summaries for portable cells to answer OEM sustainability questionnaires. Send your pack Wh, application and customer carbon template and we return the scope decision plus the matching data pack.
