EU Battery Regulation — Battery Supply Chain Due Diligence Obligations
ENFORCEMENT TIMELINE
Effective August 18, 2025 (mandatory for economic operators above the specified net turnover threshold)
Overview
Under Chapter VII of the EU Battery Regulation (Regulation (EU) 2023/1542), economic operators placing batteries on the EU market with an annual net turnover exceeding €40 million are required to establish, operate, and obtain third-party verification of a human rights and environmental due diligence policy covering the sourcing of key raw materials and chemical compounds such as cobalt, natural graphite, lithium, and nickel.
Enforcement Timeline
August 17, 2023: The new Battery Regulation enters into force.
August 18, 2025: Economic operators with a net turnover of €40 million or more become subject to the requirement to establish a supply chain due diligence policy and obtain audit and certification from a third-party conformity assessment body.
Ongoing, annually thereafter: Due diligence reports must be published and reviewed periodically.
Business Impact
Companies that sell or export electric vehicle batteries, industrial batteries, and SLI (starting, lighting, ignition) batteries, whether standalone or embedded in other products, into the EU market must establish a management system aligned with OECD guidance, ensure traceability down to the smelter and refiner level, and pass audits conducted by third-party verification bodies.