---
title: Supply-chain due diligence for battery materials
deck: From 18 August 2027, larger battery companies must run and verify due diligence on cobalt, lithium, nickel and natural graphite. Who is covered, the five steps, and what it means for the passport.
description: Battery supply-chain due diligence under the EU Battery Regulation: who is covered, the five steps, verification, reporting and passport fields.
category: Regulation
date: '2026-10-31'
image: /assets/tiles/b-0-1.jpg
order: 11
---

The Battery Regulation asks companies placing batteries on the EU market to check how the raw materials in them were sourced (Arts. 48 to 52). The duty was due to start in August 2025; Regulation (EU) 2025/1561 moved it to **18 August 2027**.

## Who is covered

Companies with net turnover of **€40 million or more** in the financial year before last are covered, as are smaller companies that belong to a group above that figure on a consolidated basis (Art. 47). Companies placing re-used, repurposed or remanufactured batteries are exempt where those batteries were already on the market before.

Proposals discussed in 2025 and 2026 would raise the threshold further and make reporting less frequent; nothing had been decided as of October 2026. Plan on the current rules.

Below the threshold, due diligence still reaches you. The passport has due diligence fields, and your customers will ask for supplier reports whether or not you must publish your own.

## The materials

Annex X covers **cobalt, natural graphite, lithium and nickel**, and compounds made from them for active materials. The risks are well documented: child labour and unsafe conditions in artisanal cobalt mining, water stress and community conflict around lithium extraction, deforestation and emissions in nickel processing, and pollution from graphite production.

## The five steps

The process follows the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals:

1. **Management system.** A written policy, someone responsible, due diligence built into purchasing, and the resources to run it. The policy goes into supplier contracts (Art. 49(1)(e)).
2. **Identify risks.** Map suppliers from your direct supplier back to the raw material source, with a traceability or chain-of-custody system (Art. 49(1)(d)).
3. **Respond to risks.** A plan reported to senior management: contract clauses, supplier audits, industry programmes, and changing supplier as a last resort. You may keep trading while mitigating, or suspend; consult the people affected before deciding (Art. 50).
4. **Third-party verification.** By a notified body designated by a member state (listed in the EU NANDO database). An auditor you choose yourself doesn't satisfy this.
5. **Report.** A public report every year on the risks, what you did about them and the verification results (Art. 52).

Alongside these, you need a grievance mechanism, an early-warning channel for concerns, which can be run jointly with other companies (Art. 49(1)(f)).

## The data per material

For each raw material, Art. 49(2) expects you to hold: a description and trade name, the supplier's name and address, the country of origin and the transactions back to your immediate supplier, the quantity in the battery, the notified body's verification reports, and extra information where it comes from high-risk or conflict-affected areas. Keep the records for 10 years after the last battery covered (Art. 48(3)).

## Where it meets the passport

The passport doesn't reproduce the reports. It carries a reference to your policy, a summary of the third-party audit, the high-risk areas identified and the measures taken, and links to the full report. The QR code on every battery (not just passport batteries) also links to the due diligence report once the duty applies.

## Getting started

- Use standard questionnaires, such as those from the Responsible Minerals Initiative or the Global Battery Alliance, rather than inventing your own.
- Join an industry programme (RMI, IRMA, GBA) to share audits.
- Write the policy into supplier contracts now; renegotiating later is harder.
- Review the risk analysis at least once a year, and again when suppliers or risks change.

## FAQ

### When does battery supply-chain due diligence start?

On 18 August 2027. It was originally due in August 2025 and was postponed by Regulation (EU) 2025/1561.

### Which companies must do battery due diligence?

Those with net turnover of €40 million or more in the financial year before last, or belonging to a group above that figure, that place batteries on the EU market.

### Which raw materials are covered?

Cobalt, natural graphite, lithium and nickel, and the compounds made from them for active materials (Annex X).

## Sources

- [Supply-chain due diligence for batteries](https://dpphero.com/en/blog/supply-chain-due-diligence), DPP Hero
- [Battery passport checklist 2027](https://dpphero.com/en/blog/battery-passport-checklist-2027), DPP Hero
- [EUBR compliance checklist](https://kezzler.com/eubr-compliance-checklist/), Kezzler