From 18 August 2025, due diligence obligations apply to economic operators involved in the supply chain of batteries sold on the EU market, whether incorporated to a product or not. The provisions do not apply to economic operators with a net turnover of less than EUR 40 million (including the group they are part of).
However, the initial deadline will likely change. On 23 May 2025, the Commission published a consultation to collect feedback on the proposal to amend the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations. The amendment would delay the initial deadline of 18 August 2025 by two years.
What is a battery due diligence policy?
The EU Battery Regulation defines battery due diligence as “the obligations of an economic operator in relation to its management system, risk management, third-party verifications and surveillance by notified bodies, and disclosure of information, for the purpose of identifying, preventing and addressing actual and potential social and environmental risks linked to the sourcing, processing and trading of the raw materials and secondary raw materials required for battery manufacturing, including by suppliers in the chain and their subsidiaries or subcontractors” (Article 3.44). That is to say, this policy entails the implementation of procedures to manage risks related to human rights as well as environmental protection.
Due diligence requirements to address social and environmental risks
Battery due diligence obligations apply to economic operator of all types of batteries with regard the four raw materials nickel, cobalt, natural graphite, lithium, and the chemical compounds derived from these raw materials. Essentially, the introduction of these provisions tackle social and environmental risks tied to obtaining and handling raw materials for battery production.
In terms of social risks, battery due diligence policies should address the risks related to human rights abuses. In fact, such abuses are prevalent in resource-rich, conflict-affected, and high-risk areas. These policies should aim to protect human health, labour rights, community life, including that of Indigenous peoples, the rights of children, and gender equality, in accordance with international human rights law.
As for environmental risks, battery due diligence policies should address threats to the natural environment and biological diversity, as well as risks related to climate change.
A notified body has to verify the due diligence policies of economic operators (third-party verification).
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