EU Battery Regulation: Start of due diligence obligations postponed to 2027
Due diligence obligations for battery raw materials were originally supposed to take effect on 18 August 2025. However, the EU Commission has now postponed this start date by two years. The deadline for publishing the relevant guidelines has also been extended. The postponement of the effective date of the EU Battery Regulation was published in the Official Journal of the European Union on 30 July. The new deadline is 18 August 2027. Furthermore, the deadline by which the European Commission must publish guidelines on due diligence obligations has been postponed from 18 February 2025 to 26 July 2026.
For many companies that place batteries on the market in the EU, this is initially a relief, as the requirements for supply chain analysis and implementation of the regulations are complex and time-consuming. At the same time, many questions remain unanswered, such as when clear guidelines can be expected and how binding the new timetable really is.
Let's take a closer look at the EU Commission's proposal, the background to the planned postponement and what it all means for affected companies.
What do the due diligence obligations in the EU Battery Regulation regulate?
With the EU Battery Regulation (EU) 2023/1542 and the EU Supply Chain Directive (CSDDD), the European Union is pursuing the goal of making the entire battery value chain more sustainable. A central component of this are the so-called due diligence obligations. Both sets of regulations aim to create a sustainable, ethically responsible and transparent supply chain, but focus on different industries and products. Companies in the battery sector must comply with both regulations.
This affects companies that supply batteries or battery-powered products to the EU market and use certain raw materials such as cobalt, lithium, nickel or graphite. In future, they will have to ensure that these raw materials are extracted and traded in compliance with environmental and social standards. Specifically, the regulation requires these companies to analyse their supply chains, identify risks and take measures to minimise them. This includes, for example, identifying and avoiding human rights risks such as child labour or poor working conditions in raw material extraction. Companies must also publish reports on their due diligence measures and undergo audits by recognised verification systems. The due diligence obligations are based on international standards, such as the OECD Guidelines for Responsible Supply Chain Management of Minerals. They are therefore not purely an EU instrument, but part of a larger trend towards greater responsibility along global supply chains.
Who is affected? What are the requirements?
The due diligence obligations apply to so-called ‘economic operators’ who place batteries or battery-powered products on the market in the EU. These include, in particular, manufacturers, importers and distributors whose products contain certain critical raw materials. Companies outside the EU may also be affected if they supply products to the European market.
The key requirements include:
Risk assessment in the supply chain: Companies must find out where their raw materials come from and under what social and environmental conditions they were obtained.
Introduction of a due diligence system: This includes guidelines for responsible procurement, contractual requirements for suppliers and internal control mechanisms.
Transparency obligations: Affected companies must regularly report publicly on their measures and results.
External verification: The implementation of due diligence obligations must be monitored by recognised verification systems or independent third parties.
The requirements do not apply across the board to every battery, but only to certain categories such as traction batteries (e.g. in electric vehicles), industrial batteries and batteries with a certain threshold value of critical raw materials. The exact threshold values and definitions are specified in the regulation.