On December 31, 2025, the General Office of the Ministry of Industry and Information Technology issued the Notice on Carrying out Carbon Footprint Reporting for Automotive Traction Batteries (hereinafter referred to as “the Notice”), requiring all automotive traction batteries with a rated energy greater than 2 kilowatt-hours (kWh) sold in China undergo carbon footprint reporting since the publication date of the Notice.

The entities responsible for reporting include not only manufacturers and importers of traction batteries but also road vehicle manufacturers that self-assemble traction batteries.

The reporting work will be implemented in two phases:

-    From the issuing date of the Notice until December 31, 2026, it will be a pilot phase, during which each manufacturer must complete reporting for at least five typical product models covering all chemical systems used;

 -   Starting January 1, 2027, normalized management begins, requiring all relevant products to carry out carbon footprint calculation and verification as stipulated.

Enterprises must register on the designated information platform and complete, in sequence, the submission of data quality control measures, product activity data, self-calculation based on the platform's background database, and finally upload a report verified by an independent third-party institution.

The carbon footprint is required to be calculated using a full lifecycle methodology. Its value is the sum of carbon emissions from four stages—material acquisition, production manufacturing, distribution and transportation, and recycling and reuse—divided by the total energy provided by the battery to the vehicle over its service life. The calculation rules specifically prioritize determining cycle life based on actual testing per the national standard GB/T 31484 Cycle life requirements and test methods for traction battery of electric vehicle (currently effective version is 2015 version, and an amendment list has also come into force in the same year) and recognize green power certificates and regional grid emission factors to more accurately reflect the carbon emissions profile.

The implementation of these requirements involves collaboration across multiple parties in the industrial chain. In addition to the reporting entities themselves:

-    Upstream suppliers of raw materials, components, transportation, and recycling serve as collaborative entities providing relevant data;

-    Third-party verification bodies are responsible for certification; research institutions, industry organizations, etc., can contribute as factor data providers to build the background database;

 -   Relevant experts may participate in review, evaluation, and policy research.

In all, the Notice encourages enterprises to establish digital carbon management platforms and green supply chains, plans to integrate product carbon footprint evaluation results into automobile consumption policies, government procurement standards, and zero-carbon factory assessments, and is committed to promoting mutual recognition and alignment between domestic calculation rules, background data, and international systems.

For foreign stakeholders, especially those sell or use traction battery for products sold in China, it is advised to immediately initiate compliance benchmarking to assess the gap between their current product carbon footprint and the Chinese calculation rules, identifying critical data gaps. Building localized data management capabilities for the Chinese market is necessary, which includes arranging for required in-country testing. It is also essential to ensure that the supply chain (especially partners within China) can provide compliant and traceable carbon activity data.