According to the EU's official consultation portal, the delegated act setting the carbon footprint calculation methodology under Article 7 of the EU Batteries Regulation (2023/1542) had not moved to the adoption stage as of 23 September 2026, and the portal still shows the planned adoption period as "Q3 2025". In an assumed 8 GWh/year plant producing two models, allocating the same 200,000,000 kWh of electricity by floor area, operating time, capacity or cell count makes the per-cell electricity of model A swing from −27.3% to +10.3% against the process-metered value of 7.860 kWh. Area-based allocation reverses the low-carbon ranking of the two models, and capacity-based allocation has the smallest total…