🔋 EV Battery × EU Regulation — Corporate Response Case Studies
Track how global companies are responding to major environmental regulations, categorized by framework. Identify stances, strategies, and key implementation hurdles.
📋 About the Listed Information (Disclaimer)
The information on this page is compiled from official disclosures. Stances evolve as regulatory definitions shift. Verify with primary sources before making business decisions.
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EU Batteries Regulation
Jurisdiction / RegionEuropean Union (EU)
Key TimelineThe battery passport applies from 18 February 2027 (EV, LMT and industrial batteries over 2 kWh). Raw material due diligence obligations apply from 18 August 2027 (postponed by Regulation (EU) 2025/1561). Recycled-content requirements apply from August 2031. The carbon footprint declaration does not yet apply, even for EV batteries, because the delegated act on the calculation method has not been adopted (as of September 2026).
Scope & CoverageAll batteries placed on the EU market (portable, starting-lighting-ignition (SLI), light means of transport (LMT), electric vehicle and industrial batteries)
GRI Regulatory Summary
A pioneering regulation that manages the entire battery life cycle — raw material sourcing, environmental impact and recycling — digitally through the battery passport. It requires transparency across the entire EV battery supply chain.
Opened a Circular Factory in the UK; co-developing solid-state battery cathodes with Sumitomo Metal Mining.
Data sharing across its Japanese supply chain for the battery passport
Glencore
Glencore plc
SwitzerlandMining & Commodity Trading
Adapting
⚡ Positions itself as the only major Western copper and cobalt producer in the DRC — first to export cobalt under the DRC's quota system, and took battery recycling in-house by acquiring Li-Cycle in August 2025
Glencore mines, processes and trades copper and cobalt from its two DRC operations, Mutanda Mining (Mumi) and Kamoto Copper Company (KCC). The company describes itself as the only major Western producer of copper and cobalt in the DRC; in 2025 the two operations produced 247.8 kt of copper and 33.5 kt of cobalt. This places Glencore at the very top of the supply chain covered by the EU Battery Regulation's supply chain due diligence obligations, which apply from 18 August 2027. The DRC suspended cobalt exports in February 2025 and replaced the ban with an export quota system in October 2025 (18,125 t for the rest of 2025 and 96,600 t a year for 2026 and 2027). Glencore was the first company to export cobalt under the new system. On the recycling side, Glencore acquired the assets of bankrupt recycler Li-Cycle in August 2025 and now runs the business as Glencore Battery Recycling. In February 2026 it signed a non-binding memorandum of understanding with the Orion Critical Mineral Consortium (Orion CMC), whose members include a US government development finance institution, to sell 40% of its interests in Mumi and KCC (implying an enterprise value of around $9 billion for the two operations, which would remain managed by Glencore). Reconciling past human rights and corruption allegations in the DRC with the transparency the EU now requires remains its biggest challenge.
🎯 Key Initiatives
April 2025: Mumi and KCC awarded The Copper Mark for responsible copper production — the first mines in Africa certified under the revised RRA 3.0 standard
October 2025: The DRC replaced its cobalt export ban (in place since February 2025) with an export quota system; Glencore became the first company to export cobalt under the new system (reported December 2025)
August 2025: Completed the acquisition of bankrupt Li-Cycle's assets (pre-processing sites in the US, Canada and Germany, the Rochester hub under construction, and intellectual property); the business continues as Glencore Battery Recycling
December 2024: Restarted, under Glencore's lead and funding, the prefeasibility study for a European recycling hub using Glencore's existing metallurgical complex at Portovesme, Sardinia, Italy
February 2026: Signed a non-binding MoU with Orion CMC to sell 40% of Glencore's interests in Mumi and KCC (enterprise value of around $9 billion; the operations would remain managed by Glencore)
⚠️ Challenges & Risks
•Past human rights and corruption allegations in the DRC: In 2022 Glencore agreed a settlement of around $180 million with the DRC government over corruption allegations. In 2024 the Business and Human Rights Resource Centre highlighted reports alleging links between Glencore's DRC copper-cobalt operations and pollution, child labour and tax evasion (Glencore has responded to the allegations). Under the EU Battery Regulation's due diligence obligations, how such allegations are addressed becomes part of customers' supplier assessments.
•Operational risks under the export quota system: Exports are capped at 96,600 t a year for 2026 and 2027, of which 9,600 t is a discretionary reserve held by the regulator ARECOMS. Forfeiture of unused quotas and shipment delays caused by administrative bottlenecks have made supply volumes harder to forecast.
•Timing of the Portovesme hub: The project began as a joint plan with Li-Cycle and became a Glencore-only plan following the acquisition. Its timing matters as a potential source of recycled material within Europe ahead of the EU Battery Regulation's recycled-content requirements, which apply from August 2031.
•Impact of the Orion CMC transaction: If completed, Orion CMC would be able to direct the sale of its share of production to nominated buyers, in line with the US–DRC Strategic Partnership Agreement. How this affects supply allocation to Europe and the provision of traceability data to downstream battery makers will depend on the final terms.
📢 2024–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Glencore shows what it means to be the most exposed company at the very top of the supply chain. It mines in the DRC, where human rights and corruption risks are high, yet must meet the traceability and transparency the EU now demands — a structural challenge for the entire cobalt supply chain, not just for Glencore. In 2025–2026 this upstream picture shifted significantly. First, the DRC government now manages supply volumes directly through export quotas, so cobalt is becoming less a commodity bought on the market and more one released through government allocation. Second, by acquiring Li-Cycle, Glencore now covers both mining and recycling within one group. Third, the MoU to sell a 40% stake to a US-backed consortium shows that DRC copper and cobalt are being drawn into US supply chain policy. For procurement teams at battery makers and automakers, Glencore is a key variable in future cobalt sourcing on two fronts: how much due diligence data it can disclose, and which markets its supply will flow to.
The DRC's export quota system, the Orion CMC transaction and the Portovesme hub plans may change. Please check Glencore's official website and announcements by the DRC authority (ARECOMS) for the latest information.
Rio Tinto
Rio Tinto plc / Rio Tinto Limited
UK / AustraliaMining
Adapting
⚡ Became a major lithium player through the Arcadium acquisition (March 2025) — two new Argentine operations started production ahead of plan in Q2 2026, while the Jadar project in Serbia, close to Europe, was paused
Rio Tinto completed its acquisition of Arcadium Lithium in March 2025, taking on lithium assets in Argentina, Canada and elsewhere. Lithium now sits in the Aluminium & Lithium business, one of the group's pillars alongside iron ore and copper. In Argentina, Fénix 1B (10 ktpa) and Sal de Vida (15 ktpa) achieved first production ahead of plan in Q2 2026. At Rincon in Salta province, a starter plant began operating in May 2025, and an expansion to a total of 60 ktpa (approved in December 2024) is targeting first production in 2028. Rio Tinto's share of lithium production in H1 2026 was 27.3 kt LCE, up 53% year on year. Meanwhile, the Jadar project in Serbia — a large lithium project close to Europe — was placed on care and maintenance in November 2025, reflecting Chief Executive Simon Trott's focus on prioritising capital since he took office in August 2025. As an upstream supplier, Rio Tinto plays a growing role in providing the carbon footprint and due diligence data that battery makers need under the EU Battery Regulation.
🎯 Key Initiatives
March 2025: Completed the acquisition of Arcadium Lithium (around $6.7 billion), adding lithium assets in Argentina, Canada and elsewhere
December 2024: Approved around $2.5 billion for the Rincon expansion (60 ktpa including the starter plant; first production in 2028 with a three-year ramp-up)
Q2 2026: Fénix 1B (10 ktpa) and Sal de Vida (15 ktpa) in Argentina achieved first production ahead of plan
November 2025: Placed the Jadar project in Serbia on care and maintenance
Nemaska Lithium in Quebec, Canada (Rio Tinto 53.9%): first production still planned for 2028, but construction at the Bécancour plant slowed during 2026
⚠️ Challenges & Risks
•Distance from European supply: Production is centred on Argentina and Canada, and pausing Jadar has pushed large-scale lithium supply near Europe further away. Under the EU Battery Regulation's due diligence obligations (from 18 August 2027), water use at South American brine operations and relationships with local and Indigenous communities may come under scrutiny.
•Ramping up new operations: The new operations are still ramping up, and must show they can deliver the quality and reliable supply battery makers require. At Rincon, work is focused on stabilising the reactor process at the starter plant.
•Providing carbon footprint and due diligence data: Rio Tinto needs systems to supply consistent data to downstream battery makers across different production methods (brine using direct lithium extraction or evaporation ponds, and hard rock) and multiple countries.
•Concentration in Argentina: Its main expansion projects are concentrated in Argentina, leaving it exposed to policy changes such as currency or export controls.
📢 2024–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Rio Tinto's acquisition of Arcadium shows an iron ore and copper major moving seriously into lithium, the upstream of the battery supply chain. With its new Argentine operations starting production ahead of plan, its position as a large-scale lithium supplier outside China is clearly growing. At the same time, pausing Jadar near Europe while concentrating production in South and North America sits at some distance from the EU's goal of securing raw materials within or near Europe. For procurement teams at battery makers and automakers, the takeaway is that Rio Tinto is set to become one of the lithium suppliers they cannot ignore. With the EU Battery Regulation's due diligence and carbon footprint requirements in mind, it pays to start sharing data now — including which site and which production method the material comes from.
Lithium prices, project progress and regulatory developments change. Please check Rio Tinto's official investor materials for the latest information.
BHP
BHP Group Limited
AustraliaMining (Nickel)
Reactive
⚡ Temporarily suspended Western Australia Nickel from October 2024, with the decision to be reviewed by February 2027 — a test of whether the EU Battery Regulation can make the market value low-carbon sulphide nickel
BHP temporarily suspended its Western Australia Nickel business (Nickel West and the West Musgrave project) from October 2024, citing global oversupply and falling nickel prices. It recognised a pre-tax impairment of around $3.5 billion in February 2024, followed by a further pre-tax impairment of around $0.3 billion when it decided to suspend operations. To keep the option of a restart, BHP continues to invest around A$450 million (about US$300 million) a year in the facilities, and intends to review the suspension by February 2027. In August 2025 it was reported to be considering a possible sale. BHP's sulphide nickel is regarded as less carbon-intensive than the coal-power-heavy processing routes that have expanded in Indonesia. If the EU Battery Regulation's carbon footprint rules take full effect, low-carbon nickel could gain value. For now, however, while operations are suspended, BHP has no nickel to supply to downstream battery makers.
🎯 Key Initiatives
February 2024: Announced a review of Western Australia Nickel and recognised a pre-tax impairment of around $3.5 billion
July 2024: Decided to temporarily suspend operations (suspended in October 2024, handover completed by December 2024), with a further impairment of around $0.3 billion
Continues to invest around A$450 million a year to maintain the facilities for a potential restart, and set up an A$20 million community fund
Intends to review the suspension decision by February 2027
August 2025: Reported to be considering a sale of the business
⚠️ Challenges & Risks
•Economics of a restart: As long as Indonesian oversupply continues, a sustained recovery in nickel prices is hard to foresee. Unless low-carbon nickel earns a price premium, it will be difficult to close the cost gap.
•Timing of regulatory support: The EU Battery Regulation's carbon footprint declaration, performance classes and maximum thresholds only take effect once the Commission's delegated acts are in place. When the market starts to value low-carbon nickel depends on how quickly these rules are finalised.
•Impact of a sale: A sale could further narrow the sources of low-carbon nickel outside China and Indonesia.
•Mounting holding costs: For as long as the suspension continues, maintenance costs of around A$450 million a year keep accumulating.
📢 2024–2025 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
The suspension of BHP's Western Australia Nickel business is the market's current answer to a key question: can the EU Battery Regulation give low-carbon raw materials a price advantage? The lower carbon intensity of sulphide nickel is a real strength, but the regulatory mechanisms that would reflect it in market prices are still being put in place. From GRI's perspective, what matters is that BHP's review deadline of February 2027 coincides with the EU Battery Regulation's battery passport requirement (18 February 2027) and due diligence obligations (18 August 2027). Whether a source of low-carbon nickel outside China and Indonesia survives will be decided just as the regulation starts to bite. For procurement teams at battery makers and automakers, BHP's decision is a key assumption for long-term nickel sourcing strategy.
Nickel prices and BHP's decision (to be reviewed by February 2027) may change. Please check BHP's official investor materials for the latest information.
Sumitomo Metal Mining
Sumitomo Metal Mining Co., Ltd.
JapanBattery Materials & Non-Ferrous Metals
Adapting
⚡ A leading cathode material maker spanning resources, smelting and battery materials — shelved capacity expansion as EV demand slowed, while signing a joint development agreement with Toyota for mass production of cathode materials for all-solid-state batteries
Sumitomo Metal Mining (SMM) covers everything from resource development for nickel and copper to smelting and battery materials such as cathodes, and has supplied cathode materials for electrified vehicles for more than 20 years. For nickel and cobalt, which fall under the EU Battery Regulation's due diligence obligations (from 18 August 2027), SMM carries out sourcing due diligence in line with international guidance, and in December 2025 published a due diligence report on its copper, nickel and cobalt raw materials. In December 2024 it decided to invest around ¥28 billion in facilities at its Hyuga Smelter (Miyazaki Prefecture) to produce nickel matte from ferronickel (completion planned in FY2027; certified by Japan's Ministry of Economy, Trade and Industry under its plan to secure critical mineral supply). This will allow part of the raw material it has imported from overseas to be produced in Japan. Meanwhile, as EV demand slowed, it shelved investment to expand battery material capacity in July 2025. In October 2025 it signed a joint development agreement with Toyota for mass production of cathode materials for all-solid-state batteries.
🎯 Key Initiatives
December 2025: Published a due diligence report on responsible sourcing of copper, nickel and cobalt raw materials
December 2024: Decided to invest around ¥28 billion in nickel matte production facilities at the Hyuga Smelter (construction from 2025, completion planned in FY2027; certified under METI's plan to secure critical mineral supply)
July 2025: Shelved investment to expand battery material capacity as EV demand slowed
October 2025: Signed a joint development agreement with Toyota for mass production of cathode materials for all-solid-state batteries (joint research since around 2021)
April 2024: With Mitsubishi Corporation, entered a binding cooperation agreement on the Kalgoorlie Nickel Project – Goongarrie Hub in Australia (funding the definitive feasibility study to earn a 50% stake in the project company)
⚠️ Challenges & Risks
•Restoring profitability in battery materials: With slowing EV demand and weak nickel prices, the battery materials business faces a tough earnings environment, and restoring profitability while holding back on expansion is a key challenge.
•Preparing for the battery passport: Ahead of the battery passport requirement on 18 February 2027, SMM needs mechanisms to provide downstream battery makers with data such as mine of origin and processing routes.
•Deepening due diligence to the mine level: The EU Battery Regulation's due diligence obligations require risk management that reaches back to the mine. Human rights and environmental due diligence needs to be strengthened, including at overseas mines in which SMM holds interests.
•Mass production technology for solid-state cathodes: To meet Toyota's target of commercialisation in 2027–2028, SMM needs production technology that delivers performance, quality and cost for cathode materials with different requirements from those for liquid-electrolyte batteries.
📢 2024–2025 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Sumitomo Metal Mining is one of the few companies that can build its EU Battery Regulation compliance on owning resources, smelting and materials within one group. Being able to connect data from the mine to the cathode in-house is a major advantage for the traceability that due diligence obligations and the battery passport require. Its investment at the Hyuga Smelter can also be read as a move to improve supply chain transparency and stability by producing part of its raw material in Japan. At the same time, it is holding back on expansion as EV demand slows while laying groundwork for the next generation through its solid-state cathode work with Toyota — balancing short-term market response with long-term technology investment. For procurement teams at battery makers and automakers, now is the time to agree the scope and format of data sharing with SMM ahead of the 2027 battery passport requirement.
EV market trends, nickel prices and regulatory developments change. Please check Sumitomo Metal Mining's official investor materials and sustainability reports for the latest information.
Umicore
Umicore NV/SA
BelgiumBattery Materials & Recycling
Proactive
⚡ A European pioneer in the responsible sourcing, battery passport and recycling that the EU Battery Regulation requires — hit by the EV slowdown with a large impairment and a halted Canadian plant in 2024, and now rebuilding under its 2025 CORE strategy
Belgium's Umicore is a European company that makes cathode materials and recycles batteries. It introduced a responsible cobalt sourcing framework early on and, as a founding member of the Global Battery Alliance (GBA), has been involved in standardising the battery passport. In Hoboken, Belgium, it operates battery recycling technology that combines pyrometallurgical and hydrometallurgical processes. The EV slowdown, however, hit Umicore directly: in 2024 it recognised an impairment of around €1.6 billion in its battery materials business, and in November that year it paused construction of its cathode materials plant under construction in Ontario, Canada. Its CORE strategy, announced in March 2025, aims to maximise cash generation from its foundation businesses such as catalysis and precious metals refining, while grouping cathode materials and battery recycling into a single Battery Materials Solutions business group to recover value in cathode materials. Umicore describes 2025 as a turning point, and plans to keep strict capital discipline in cathode materials in 2026.
🎯 Key Initiatives
March 2025: Announced its CORE strategy — maximising cash generation from its foundation businesses (such as catalysis and precious metals refining) and combining cathode materials and battery recycling into the Battery Materials Solutions business group
November 2024: Paused construction of its Loyalist cathode materials plant in Canada, alongside cost-saving measures
2024: Recognised an impairment of around €1.6 billion in its battery materials business
Took part in the European Battery Pass project, contributing to work on battery passport data requirements and standardisation (the project has concluded)
February 2026: Reported full-year 2025 results — solid performance driven by its foundation businesses, and continued pursuit of its mid-term plan to recover value in cathode materials
⚠️ Challenges & Risks
•Preparing for recycled-content requirements: From August 2031, the EU Battery Regulation requires batteries to contain minimum shares of recycled material (16% cobalt, 6% lithium and 6% nickel). For now, Umicore's battery recycling business is focused on technology optimisation (with 2026 spending expected to be broadly in line with 2025), and scaling up recycled-material supply within Europe ahead of the requirements is a key challenge.
•Recovering value in cathode materials: Restoring profitability in cathode materials amid a volatile EV market and intense price competition from Chinese and Korean rivals is a mid-term challenge.
•Future of the Canadian plant: Whether the paused Loyalist plant is restarted depends on North American EV demand and customer developments.
•Returning years of up-front investment: Its long-standing investment in responsible sourcing, recycling and data infrastructure is unlikely to translate into earnings until the regulation's requirements fully apply between 2027 and 2031.
📢 2024–2026 official announcements and investor materials🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Umicore is the most paradoxical case in our EU Battery Regulation series. The company that has most faithfully embodied the regulation's principles has been hit hardest by the slowdown in the EV market on which the regulation depends. The key lesson from GRI's perspective is that being ahead of regulation only pays off once the market matures. The responsible sourcing, traceability and recycling capabilities Umicore has built over many years are real, but they will only turn into earnings once the EU Battery Regulation's obligations (2027–2031) take full effect. The CORE strategy can be read as a realistic shift: using cash from its foundation businesses to fund its up-front investment while it waits for the regulation to bite. For procurement teams at battery makers and automakers, Umicore's recycling and battery passport infrastructure within Europe is likely to become more important as the 2031 recycled-content requirements approach.
EV market trends, decisions on the Loyalist plant and regulatory timelines change. Please check Umicore's official investor materials for the latest information.
CATL
Contemporary Amperex Technology Co., Limited
ChinaBattery Cell Manufacturing
Adapting
⚡ The world's largest battery maker is ramping up local production in Europe — trial cell production began at its Debrecen plant in Hungary in September 2026 (later than first planned), and a joint venture plant with Stellantis is planned in Spain
CATL is the world's largest battery maker, with a 39.2% share of the global EV battery market in 2025. In Europe, following its plant in Thuringia, Germany, it is building one of Europe's largest battery plants in Debrecen, Hungary (100 GWh planned; 34 GWh in the first phase). The site has produced battery modules since autumn 2024; for cells, CATL obtained its occupancy permit in August 2026 and began trial production on the first two lines on 22 September 2026. It had originally aimed to start production in late 2025 or early 2026, so cell production began later than planned. In December 2024 CATL and Stellantis announced a joint venture to invest up to €4.1 billion in an LFP battery plant in Spain. Its subsidiary Brunp processed more than 120,000 tonnes of used batteries and other material in 2024. At the same time, the EU Battery Regulation's due diligence obligations (from 18 August 2027) require third-party-verifiable disclosure across an upstream supply chain that spans China, the DRC and Indonesia.
🎯 Key Initiatives
22 September 2026: Began trial cell production on the first two lines of its Debrecen plant in Hungary (34 GWh in the first phase, 100 GWh planned); modules have been produced there since autumn 2024
December 2024: Announced a joint venture with Stellantis to invest up to €4.1 billion in an LFP battery plant in Spain
Vertically integrated recycling through its subsidiary Brunp, which processed more than 120,000 tonnes of used batteries and production scrap in 2024
Expanding local production in Europe while decarbonising its plants and managing supplier emissions data
⚠️ Challenges & Risks
•Upstream due diligence: The EU Battery Regulation's due diligence obligations (from 18 August 2027) require third-party-verifiable due diligence reaching back to mining and refining. With its upstream concentrated in China, the DRC and Indonesia, this is a structural challenge for CATL.
•Preparing for carbon footprint rules: The EU Battery Regulation's carbon footprint declaration, performance classes and maximum thresholds do not yet apply even to EV batteries, because the delegated act setting the calculation method has not been adopted (as of September 2026). Depending on where the future thresholds are set, supply of China-made batteries to Europe could be affected.
•Ramping up the European plant: Obtaining permits and other steps took longer than expected at Debrecen, delaying the start of cell production. The immediate challenges are moving to series production and stabilising quality.
•Data sharing for the battery passport: Ahead of the battery passport requirement (18 February 2027), which European automakers must meet, CATL needs systems to collect data from multi-tier suppliers in China and provide it in the EU format.
📢 2024–2026 official announcements and investor materials🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
CATL is the largest example of a non-EU company responding to the EU Battery Regulation through local production. For European automakers, doing business with CATL is becoming less an option and more a given. Its strategy of absorbing the costs of local production, due diligence and the battery passport through its unmatched scale and technology is rational. Yet the delayed start at Debrecen shows that bringing a large plant online in Europe is not easy. And due diligence across an upstream supply chain spanning China, the DRC and Indonesia is a structural issue that scale alone cannot solve. For Japanese component and materials suppliers reading GRI, the takeaway is that the due diligence and data requests CATL makes of its suppliers, as part of its EU compliance, may cascade down to them as well.
EV market trends, EU regulatory timelines and plant operations change. Please check CATL's official investor materials and announcements for the latest information.
LG Energy Solution
LG Energy Solution, Ltd.
South KoreaBattery Cell Manufacturing
Adapting
⚡ A Korean battery major broadening into energy storage systems (ESS) as EV demand slows — with its Polish plant as its European base and an order backlog of over 440 GWh for its 46-Series cylindrical cells
LG Energy Solution (LGES) is a Korean battery maker that operates one of Europe's largest battery plants, in Wrocław, Poland. As EV demand has slowed, it has broadened its business, for example by converting EV production lines to energy storage systems (ESS). In full-year 2025 its revenue was KRW 23.7 trillion (down 7.6% year on year), while operating profit rose 133.9%. Its Polish plant began volume production of LFP and other batteries in the second half of 2025. In February 2026 LGES acquired Stellantis's 49% stake in their Canadian joint venture NextStar Energy, making it a wholly owned subsidiary, and now uses the plant for ESS production. In Q1 2026 it posted an operating loss of KRW 207.8 billion, reflecting ramp-up costs at its ESS sites, but won more than 100 GWh of new orders for its 46-Series cylindrical cells, lifting its backlog to over 440 GWh (as of end-April 2026). Ahead of the EU Battery Regulation's battery passport (18 February 2027) and due diligence obligations (18 August 2027), its ability to provide data to European automakers will be put to the test.
🎯 Key Initiatives
H2 2025: Began volume production of LFP and other batteries at its Polish plant, extending its line-up into mid- and low-price segments
February 2026: Acquired Stellantis's 49% stake in NextStar Energy (Canada), making it a wholly owned subsidiary operated as an ESS production site
Q1 2026: Won more than 100 GWh of new orders for its 46-Series cylindrical cells, lifting the backlog to over 440 GWh (as of end-April 2026)
Building out an ESS production network in North America, targeting more than 50 GWh of capacity by the end of 2026
Started producing 4695 cells at its Ochang plant in Korea in late 2025, with production of a range of 46-Series cells planned at its Arizona plant from late 2026
⚠️ Challenges & Risks
•Returning to profit: In Q1 2026 LGES posted an operating loss, driven by ramp-up costs at new ESS sites and a weaker product mix from lower sales of pouch-type EV batteries in North America.
•Data sharing for the battery passport: Ahead of the February 2027 requirement, LGES needs systems to collect and provide data such as mine of origin, carbon footprint and recycled content from materials suppliers spread across Korea, Japan, China and elsewhere.
•A changed basis for recycling partnerships: Li-Cycle, with which LGES partnered in 2022, went bankrupt in 2025 and was acquired by Glencore. Its recycling set-up for the EU Battery Regulation's recycled-content requirements (from August 2031) will need to be rebuilt on a new basis.
•Intensifying competition in Europe: With CATL's Hungarian plant coming online, competition with Chinese rivals in the European market will intensify further.
Sources:
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
LG Energy Solution shows how an early mover in Europe adapts to a changing market. Despite having one of Europe's largest battery bases in Poland, it responded to slowing EV demand pragmatically by diversifying into ESS — a third path between CATL, which is pressing ahead with European investment, and Umicore, which has held back on major investment. Stellantis's exit from the NextStar joint venture and LGES's shift of the plant to ESS can also be read as the market growing more cautious about the EV-led battery demand growth that the EU Battery Regulation assumes. For Japanese component and materials suppliers reading GRI, the takeaway is that LGES's Polish plant is set to become a hub for battery passport data for European automakers. Companies supplying LGES with cathodes, electrolytes, separators and other materials will need to prepare the data the battery passport requires through their relationship with LGES.
EV and ESS market trends, plant operations and regulatory timelines change. Please check LG Energy Solution's official investor materials for the latest information.
Panasonic Energy
Panasonic Energy Co., Ltd.
JapanBattery Cell Manufacturing
Adapting
⚡ Mass-produces batteries in North America, mainly for Tesla — opened its Kansas plant in July 2025, while mass production of its 4680 cell keeps slipping and it broadens into batteries for data centres
Panasonic Energy has long mass-produced cylindrical lithium-ion batteries in North America, mainly for Tesla. On 14 July 2025 it began volume production of 2170 cells at its new plant in De Soto, Kansas (planned annual capacity of around 32 GWh). Meanwhile, although it completed preparations for mass production of its next-generation 4680 cell at its Wakayama plant in Japan, it is still waiting for a firm customer order, and the start of mass production — previously targeted for the end of March 2026 — has been postponed again. As EV demand has slowed, it has repurposed some 2170 lines at its Suminoe plant in Japan for data centre energy storage systems, and in June 2026 announced plans to mass-produce battery cells for data centres at the Kansas plant by FY2028 (the year ending March 2029). For recycling, it receives recycled materials from Redwood Materials in the US. Because it has no manufacturing sites in the EU, its response to the EU Battery Regulation is mainly indirect, through automakers such as Tesla that sell in Europe.
🎯 Key Initiatives
14 July 2025: Began volume production of 2170 cells at its De Soto, Kansas plant (planned annual capacity of around 32 GWh)
4680 cell: Completed preparations for mass production at its Wakayama plant, but still awaiting a firm customer order; the target of starting mass production by end-March 2026 was postponed again (reported May 2026)
Repurposed some 2170 lines at its Suminoe plant for data centre energy storage systems
June 2026: Announced plans to mass-produce battery cells for data centres at the Kansas plant by FY2028, allocating around ¥350 billion of its AI infrastructure investment to the Energy business
Receives recycled copper foil for its Nevada plant and recycled cathode material for its Kansas plant from Redwood Materials
⚠️ Challenges & Risks
•Uncertainty over the 4680 cell: When mass production starts depends on a firm customer order, and the timing remains unclear.
•Shifting from EVs to energy storage: Batteries for data centres are expected to become a new source of earnings, but its customer base there is not yet as established as in EVs.
•Indirect exposure to EU rules: With no sites in the EU, it will provide battery passport data through customers such as Tesla. The carbon footprint declaration does not yet apply, because the delegated act setting the calculation method has not been adopted (as of September 2026). Depending on where future maximum thresholds are set, supply of North American-made batteries to Europe could be affected.
•Handling regulations in several regions at once: With environmental and resource rules advancing simultaneously in Japan, North America and the EU, it needs more sophisticated global supply chain management.
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Panasonic Energy highlights a distinctive issue in our EU Battery Regulation series: the distance between a North America-centred production base and EU rules. With no manufacturing sites in Europe, its response to EU regulation runs indirectly through customers such as Tesla — but as long as those customers sell cars in Europe, the regulatory pressure cannot be ignored. The more fundamental issue is the delay of the 4680 cell and the shift towards batteries for data centres. The mass production of its next-generation cell has been buffeted by changes in the EV market, and its original growth scenario has been substantially rewritten. This reflects a challenge the whole industry faces, including CATL and LG Energy Solution: the mismatch between the pace of EV growth and the timeline of capital investment. For those in the battery supply chain, the takeaway is that Panasonic Energy has already built a recycled-material loop with Redwood Materials in North America — a useful model for securing a stable supply of recycled material ahead of the EU Battery Regulation's recycled-content requirements from 2031.
The 4680 mass production schedule, EV and energy storage market trends and the status of regulatory compliance change. Please check Panasonic Energy's official investor materials for the latest information.
Northvolt
Northvolt AB
SwedenBattery Cell Manufacturing
Defunct / Bankrupt
⚡ Aimed to be Europe's battery champion, embodying the EU Battery Regulation's ideals, but failed to ramp up production and went bankrupt in March 2025 — US-based Lyten has acquired its Swedish assets and aims to resume commercial production in H2 2026
Founded in Sweden in 2016, Northvolt built its business around low-carbon, hydro-powered manufacturing, recycling and traceability, aiming to become Europe's battery champion. However, it struggled to ramp up volume production at its main plant in Skellefteå (Northvolt Ett), and in June 2024 BMW was reported to have cancelled an order worth around €2 billion. After filing for Chapter 11 in the US in November 2024, Northvolt filed for bankruptcy in Sweden on 12 March 2025. US battery maker Lyten acquired Northvolt Dwa, a battery energy storage manufacturing site in Poland, in 2025, and on 27 February 2026 completed the acquisition of Northvolt's Swedish assets, including Northvolt Ett. It is restarting production of NMC cells in Skellefteå and plans to supply commercial cells to its Polish site in H2 2026. For the planned factory site in Heide, Germany, it signed an exclusive memorandum of understanding in July 2026 and is working towards a definitive agreement in Q3 2026.
🎯 Key Initiatives
12 March 2025: Filed for bankruptcy in Sweden (after filing for Chapter 11 in the US in November 2024)
2025: Lyten acquired Northvolt Dwa, a battery energy storage manufacturing site in Gdańsk, Poland
27 February 2026: Lyten completed the acquisition of Northvolt Ett and Ett Expansion (Skellefteå) and Northvolt Labs (Västerås), with plans to turn Skellefteå into an industrial hub co-locating battery manufacturing and data centres
Restarting NMC cell production in Skellefteå, with plans to supply commercial cells to its Polish site in H2 2026
July 2026: Lyten signed an exclusive MoU with KfW and others to progress the acquisition of the planned factory site in Heide, Germany (Northvolt Drei), targeting a definitive agreement in Q3 2026
⚠️ Challenges & Risks
•Feasibility of Lyten's turnaround: Lyten is restarting with NMC cells and aims in the longer term to mass-produce lithium-sulfur batteries, but whether a new technology can be manufactured at gigascale remains unproven.
•Rebuilding people and know-how: Bringing back talent dispersed by the bankruptcy and rebuilding manufacturing know-how will take time and money.
•A scaled-down plan for Heide: Lyten plans around 1,000 jobs in Heide, far fewer than the roughly 3,000 in Northvolt's original plan. The definitive agreement and permitting are the next milestones to watch.
•Lessons on public funding: Northvolt received substantial public support from the EU and national governments, and its bankruptcy highlighted the risks to public money in Europe's battery industrial policy.
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Northvolt's bankruptcy is the most important lesson running through our entire EU Battery Regulation series. The fact that the company most aligned with the regulation was the first to exit the market carries weight for policymakers, investors and industry alike. The industrial vision the EU Battery Regulation sets out — low-carbon, made in Europe, circular — points in the right direction, but it does not automatically guarantee a company's competitiveness or survival. Northvolt showed that without the industrial basics — manufacturing capability, cost control and a well-paced ramp-up — no amount of regulatory alignment will keep a company alive. Whether Lyten's turnaround becomes a second chance for Europe's battery industrial policy is the question to watch. If Lyten can first rebuild production with NMC cells and then combine future lithium-sulfur mass production with compliance on the battery passport, due diligence and carbon footprint, the industrial vision behind the EU Battery Regulation would be proven for the first time.
The status of Lyten's turnaround and of the Heide acquisition talks may change. Please check Lyten's official announcements for the latest information.
Tesla
Tesla, Inc.
USAAutomotive
Adapting
⚡ Facing the EU Battery Regulation while its European sales slump — registrations in Europe fell 26.9% in 2025 and its share of the European BEV market dropped to 8.9%
Tesla is an EV maker with a vertically integrated supply chain that it manages itself, from battery sourcing to finished vehicles. It sources batteries from several manufacturers, including Panasonic Energy and CATL, and files a Form SD with the US Securities and Exchange Commission (SEC) on the responsible sourcing of minerals. In Europe, however, it continues to struggle. Its new registrations in Europe (EU, EFTA and UK) fell 26.9% year on year to 238,656 in 2025, and its share of the European BEV market dropped from 18.2% in 2023 to 8.9% in 2025. This decline came while the European EV market as a whole was growing; alongside the rise of competitors including Chinese brands, damage to its brand image is seen as a factor. Under the EU Battery Regulation, Tesla needs to integrate supply chain data across multiple battery makers ahead of the battery passport (18 February 2027) and due diligence obligations (18 August 2027).
🎯 Key Initiatives
2025: Filed a Form SD with the SEC on responsible mineral sourcing and due diligence
Sources batteries from several manufacturers, including Panasonic Energy and CATL
Produces vehicles for Europe at its plant near Berlin, Germany (Gigafactory Berlin)
Assessed in an automaker supply chain evaluation (Lead the Charge 2025)
⚠️ Challenges & Risks
•Slumping European sales: Registrations in Europe fell 26.9% in 2025. Losing share while the European EV market grows is a business challenge on a different level from regulatory compliance.
•Integrating data across a multi-tier supply chain: Ahead of the battery passport (18 February 2027), Tesla needs to collect data such as mine of origin, carbon footprint and recycled content in a consistent format from several battery makers, including Panasonic Energy and CATL, and from the materials suppliers behind them.
•Upstream due diligence: The due diligence obligations (from 18 August 2027) require third-party-verifiable due diligence reaching into battery makers' upstream supply chains, including in China.
•Preparing for carbon footprint rules: The carbon footprint declaration does not yet apply even to EV batteries, because the delegated act setting the calculation method has not been adopted (as of September 2026). For vehicles using batteries made outside Europe, where future maximum thresholds are set could matter.
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Tesla shows most clearly that complying with regulation and competing in the market are two different things. Its vertically integrated supply chain gives it a strong foundation for the mine-to-product traceability that the battery passport requires. Yet in Europe its sales fell sharply even as the EV market as a whole grew. The key insight from GRI's perspective is that the EU Battery Regulation is only a qualification for taking part in the European market. Compliance is the minimum requirement to sell; the real competition happens on top of it. For battery materials and component suppliers, the quality of the battery passport, due diligence and carbon footprint data that Tesla requests — and their ability to provide it — will effectively determine whether they can reach the European market through Tesla.
European sales trends, the battery passport timeline and the competitive landscape change. Please check Tesla's official investor materials and announcements by the European Commission for the latest information.
Volkswagen Group
Volkswagen Group
GermanyAutomotive
Adapting
⚡ The first European carmaker to develop and produce its own battery cells — PowerCo's Salzgitter plant started up in December 2025 and is ramping up through 2026
Volkswagen Group is bringing battery cell production in-house through its battery subsidiary PowerCo. On 17 December 2025, it began producing its standardised Unified Cell at its plant in Salzgitter, Germany. In the first phase, it is building up annual capacity of up to 20 GWh through 2026, expandable to 40 GWh if needed. The first cell uses NMC chemistry and is said to offer around 10% higher energy density than current cells, and the plant runs on electricity from wind and solar power. PowerCo is expected to cover around half of the group's Unified Cell demand, with the rest supplied by external suppliers. Salzgitter serves as the model for the plants under construction in Valencia, Spain and St. Thomas, Canada. As Europe's largest automotive group, Volkswagen must meet the EU Battery Regulation's battery passport (18 February 2027) and due diligence obligations (18 August 2027) for both its own cells and cells sourced from suppliers.
🎯 Key Initiatives
17 December 2025: Began producing the Unified Cell at its Salzgitter plant — the first European carmaker to develop and produce its own battery cells
2026: Gradually ramping up Salzgitter towards annual capacity of up to 20 GWh (expandable to 40 GWh if needed)
Unified Cell: a standardised cell format designed for multiple battery chemistries; the first version is NMC, with variants such as LFP to follow
Building plants in Valencia, Spain and St. Thomas, Canada, with Salzgitter as the model for both
⚠️ Challenges & Risks
•Data sharing that includes externally sourced cells: PowerCo covers only around half of the group's Unified Cell demand, with the rest sourced from external suppliers. Meeting the battery passport and due diligence obligations requires integrating data from externally sourced cells as well.
•Cost and competitiveness of in-house production: Whether Volkswagen can recover its investment in in-house cell production amid cost competition from major Asian battery makers is an open question.
•Ramping up the next plants: The timing and scale of the Valencia and St. Thomas plants depend on how EV demand develops.
•Preparing for carbon footprint rules: In-region production powered by renewable energy could become an advantage under future carbon footprint rules. However, the declaration does not yet apply even to EV batteries, because the delegated act setting the calculation method has not been adopted (as of September 2026).
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Volkswagen's move into in-house cell production is the most concrete answer yet from a European carmaker to the EU Battery Regulation's vision of low-carbon battery manufacturing within Europe. The renewable-powered Salzgitter plant could become an advantage once carbon footprint rules take full effect. At the same time, PowerCo covers only around half of the group's cell demand, with the rest sourced externally. To meet the battery passport and due diligence obligations, Volkswagen will need to integrate data not only for its own cells but also for those it buys in. As Northvolt's bankruptcy showed, ramping up cell production in Europe is a difficult business. Whether Volkswagen can combine a successful ramp-up with cost competitiveness is a key test of Europe's battery industrial policy.
EV sales trends, plant start-up timelines and regulatory schedules change. Please check Volkswagen Group's official announcements for the latest information.
Toyota Motor
Toyota Motor Corporation
JapanAutomotive
Adapting
⚡ Expanding its BEV line-up in Europe under a multi-pathway strategy — signed a joint development agreement with Sumitomo Metal Mining for mass production of solid-state battery cathodes, and opened a circular vehicle dismantling facility in the UK
Toyota Motor is a vehicle maker pursuing a multi-pathway strategy, offering hybrids, plug-in hybrids, BEVs and fuel cell vehicles in parallel. In Europe it plans to expand its line-up of dedicated BEVs to six models by the end of 2026. Under the EU Battery Regulation, it is responsible for meeting the battery passport (18 February 2027) and due diligence obligations (18 August 2027) for the batteries in the EVs it sells in Europe. It aims to commercialise all-solid-state batteries in 2027–2028, and in October 2025 signed a joint development agreement with Sumitomo Metal Mining for mass production of cathode materials for them. Toyota runs its Battery 3R programme (rebuild, reuse and recycle) in several regions, and in March 2025 opened the Toyota Circular Factory at its Burnaston plant in the UK to recover parts and materials from end-of-life vehicles. A key challenge is sharing data across its whole supply chain, including a chain of Japanese companies such as Sumitomo Metal Mining and Prime Planet Energy & Solutions (PPES).
🎯 Key Initiatives
March 2025: Opened the Toyota Circular Factory at its Burnaston plant in the UK to recover and reuse parts and materials, including batteries, from end-of-life vehicles
October 2025: Signed a joint development agreement with Sumitomo Metal Mining for mass production of cathode materials for all-solid-state batteries
All-solid-state batteries: working with materials suppliers towards commercialisation in 2027–2028
Plans to expand its dedicated BEV line-up in Europe to six models by the end of 2026
Runs its Battery 3R programme (rebuild, reuse and recycle) in several regions
⚠️ Challenges & Risks
•Data sharing for the battery passport: Toyota needs systems to integrate data such as mine of origin, carbon footprint and recycled content — including across the chain of Japanese companies from Sumitomo Metal Mining (materials) to PPES (cells) to Toyota (vehicles) — and provide it in the EU format.
•Mass production technology for solid-state batteries: Establishing mass production processes and bringing down costs remain challenges on the way to commercialisation in 2027–2028.
•Preparing for carbon footprint rules: The carbon footprint declaration does not yet apply even to EV batteries, because the delegated act setting the calculation method has not been adopted (as of September 2026). Where batteries made outside Europe are used, the level of future maximum thresholds could matter.
•Competition in Europe's BEV market: With competition from Chinese and European rivals intensifying, whether Toyota can grow its BEV sales is an open question.
📢 2025–2026 official disclosures🕐 Verified: September 2026 Verified🔍 Last source review: 2026-09-28
GRI Editorial Comment
Toyota's approach to the EU Battery Regulation illustrates the tension between the strategic choice of one of the world's largest carmakers — its multi-pathway strategy — and the BEV-focused direction of EU regulation. Its joint development with Sumitomo Metal Mining on solid-state cathodes is consistent with the EU Battery Regulation's direction of strengthening battery competitiveness and supply chain stability through innovation. On implementing the battery passport, however, integrating data across the entire chain of Japanese companies — from Sumitomo Metal Mining to PPES to Toyota — is a challenge. For component and materials suppliers reading GRI, the takeaway is that the moment Toyota steps up its transparency requirements on suppliers through the battery passport is approaching with the February 2027 deadline. The Toyota Circular Factory in the UK is worth watching as an early investment in the in-region circular economy that EU regulation calls for.
The mass production schedule for solid-state batteries, BEV sales trends and regulatory timelines change. Please check Toyota's official investor materials and announcements by EU regulators for the latest information.
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