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Art. 49(2)● Knowledge · 20 Supply chain
Battery supply chain due diligence: the 2027 rules
Anyone placing batteries on the EU market must show from 18 August 2027 where the cobalt, natural graphite, lithium and nickel inside them came from, and which risks travel with them. Chapter VII of the EU Battery Regulation turns that due diligence into a verified procedure rather than a statement of intent - and Annex XIII pulls the outcome into the public battery passport.
18 Aug 27
Date of application
Moved by Regulation 2025/1561
EUR 40 m
Turnover limit
Article 47, group turnover counts
4
Raw materials
Cobalt, natural graphite, lithium, nickel
15
Risk categories
Annex X point 2, named one by one
In brief
- The date is 18 August 2027, no longer 2025. Regulation (EU) 2025/1561 moved the date of application in Article 48(1) by two years. The substance of the obligations stayed exactly as it was.
- Not every company is caught. Below EUR 40 million net turnover Chapter VII does not apply - but only if the group turnover stays below it too. The battery passport obligation itself knows no such threshold.
- Due diligence here means a procedure, not a promise. Management system, chain of custody, risk management, verification by a notified body and an annual public report - four articles that build on each other.
- The outcome lands in the passport. Annex XIII point 1(d) makes the responsible-sourcing information from that report publicly accessible passport content - six months after the passport itself becomes mandatory.
01 · Legal frame
What the regulation means by due diligence
"Supply chain due diligence" sounds like an attitude. In the EU Battery Regulation it is a timed process with a verification body, a report and a retention period.
Chapter VII of Regulation (EU) 2023/1542 runs from Article 47 to Article 53. It requires economic operators that place batteries on the market or put them into service to operate their own battery due diligence policy: a set of rules covering the sourcing, processing and trading of the four raw materials in Annex X, which must not merely exist but work and be verified.
The cut is narrower than in general supply chain legislation: not a company's entire value chain, but the upstream chain of the battery-relevant raw materials. Article 47 third paragraph adds that Union law on minerals from conflict-affected and high-risk areas is left untouched - both regimes apply, neither replaces the other.
Three layers that get mixed up
Chapter VII due diligence covers four raw materials and applies from 18 Aug 2027. The battery passport obligation in Article 77 covers LMT, industrial (above 2 kWh) and EV batteries and applies from 18 Feb 2027, with no turnover threshold. The recycled content requirement in Article 8 is a third exercise with dates of its own. Treating them as one project means planning either too early or too late.
02 · Scope
Who the due diligence rules bind - and who they do not
Article 47 describes scope backwards: it does not say who is caught, it says who is exempt. There are two exemptions, and both come with a catch.
Scope under Article 47
- Own net turnoverArt. 47 first para
Measured in the financial year preceding the last financial year. Staying below only exempts an operator if gate 2 holds as well. EUR 40 m.
- Group testArt. 47 first para
Where the operator belongs to a group of parent and subsidiary undertakings, the consolidated turnover counts. A small subsidiary of a large group stays in scope. EUR 40 m.
- Re-used batteryArt. 47 second para
If the battery was already placed on the market before preparation for re-use, repurposing or remanufacturing, Chapter VII does not apply to that placing.
Three worked examples
Home-storage manufacturer
- Own turnover
- EUR 62 m
- Group turnover
- no group
- Previously on the market
- no
Due diligence obligations apply
Importer of LMT batteries
- Own turnover
- EUR 18 m
- Group turnover
- EUR 24 m
- Previously on the market
- no
Below the limit - Chapter VII does not apply
Repowering shop, second-life pack
- Own turnover
- EUR 90 m
- Group turnover
- no group
- Previously on the market
- yes
Re-use - Chapter VII does not apply to this placing
The turnover limit is EUR 40 million of net turnover, measured in the financial year preceding the last financial year. The second half of the sentence decides: an operator is exempt only if it is also not part of a group of parent and subsidiary undertakings exceeding the limit on a consolidated basis. A sales subsidiary with EUR 12 million inside a billion-euro group is fully in scope.
The second exemption attaches to the individual battery, not to the company. If the battery was already on the market before preparation for re-use, repurposing or remanufacturing, Chapter VII does not apply to that new placing - the same logic that relieves second-life batteries elsewhere in the regulation, see Battery recycling and recycled content.
03 · Dates
How 18 Aug 2025 turned into 18 Aug 2027
Due diligence is the only obligation in the Battery Regulation whose start has already been postponed by law. The reason is stated openly in the recitals.
17 Aug 2023
Regulation 2023/1542 enters into force
Chapter VII is in the text, with the due diligence obligations dated to apply from 18 Aug 2025.
21 May 2025
The Commission's Omnibus IV package
Three proposals, among them one specifically on battery due diligence policies and one extending SME mitigating measures to small mid-caps.
30 Jul 2025In force
Regulation (EU) 2025/1561 in the Official Journal
Adopted on 18 Jul 2025, in force the day after publication. It changes exactly two dates in Article 48: paragraph 1 from 2025 to 2027, paragraph 5 from 18 Feb 2025 to 26 Jul 2026.
26 Jul 2026
Deadline for the Commission guidelines
Article 48(5) requires guidelines on applying Articles 49 and 50. The date was deliberately aligned with the guidance under Directive (EU) 2024/1760.
18 Feb 2027Passport duty
The battery passport becomes mandatory
The passport field for responsible sourcing therefore exists six months before the obligation that fills it.
18 Aug 2027Due diligence
Chapter VII applies
Policy, management system, risk management, verification and report have to be in place by then - not merely under way.
The stated reason is a practical warning
The recitals of Regulation (EU) 2025/1561 give three grounds: the shifting geopolitical landscape for raw material sourcing, the designation of notified bodies taking longer than expected, and due diligence schemes for battery raw materials that still have to be developed and recognised. Plan around that bottleneck rather than discover it.
The EUR 150 million limit is a proposal, not law in force
A threshold of EUR 150 million and a three-yearly reporting cycle circulate widely in trade coverage. Both come from the Omnibus IV package of 21 May 2025 and, as at the date of this article, have not entered into force. What binds is still the EUR 40 million in Article 47 and the annual report in Article 52(3). Planning on the relief means planning on a draft.
04 · Duties
Four building blocks: management system, risk, verification, report
Article 49 builds the system, Article 50 runs it, Article 51 verifies it, Article 52 publishes the outcome. Each block presupposes the one before it.
From company policy to the public passport
- Art. 49(1)Management system
Policy, standards, responsibility at top management
6 elements - Art. 49(2)Chain of custody
Traceability up to the upstream actors
6 items per raw material - Art. 50Risk management
Identify, assess, run the risk management plan
15 risk categories - Art. 51Verification
Notified body: verification report and approval decision
2 documents - Art. 52(3)Report
Reviewed annually, published on the internet
annual - Annex XIII pt. 1(d)Battery passport
Responsible sourcing, publicly accessible
public
Article 49(1) lists six elements the management system must contain. They are the core of the obligation and the part that takes longest:
1
Adopt and communicate the policy
A company battery due diligence policy covering the raw materials in Annex X point 1 and the risk categories in point 2 - communicated to suppliers and to the public.
2
Build in international standards
The policy has to incorporate standards consistent with the recognised instruments in Annex X point 4, such as the UN Guiding Principles and the OECD guidance.
3
Responsibility at top management
Oversight of the policy is assigned to the top management level, and records of the system are kept for a minimum of ten years.
4
Controls and transparency
Including a chain of custody or traceability system that identifies the upstream actors in the supply chain.
5
Policy into supplier contracts
The policy, including its risk management measures, becomes part of the contracts and agreements with suppliers.
6
Grievance mechanism
With an early-warning risk-awareness system and a remediation mechanism, based on the UN Guiding Principles. It may be run jointly or through an external body such as an ombudsman.
Article 50 then requires risks to be identified, assessed and answered with a management plan - up to suspending or discontinuing a supplier after failed attempts at mitigation. An operator that keeps trading while mitigating must first consult suppliers and affected stakeholders, expressly including local communities and government authorities.
Retention closes the loop: under Article 48(3) the documentation, including the verification report, the approval decision and the audit reports, is kept for ten years after the last battery manufactured under that policy was placed on the market.
05 · Annex X
Four raw materials, fifteen named risks
Annex X is not an annex to skim. It is the checklist risk management runs against: it names the materials, the risks and the yardstick.
Annex X: raw materials and risk categories
Raw materialsAnnex X pt. 1
- Cobalt
- Natural graphite
- Lithium
- Nickel
Their chemical compounds count too, as far as they are necessary to manufacture the active materials of the battery (point 1(e)).
Environment, climate, health2 (a)
- air, including greenhouse gas emissions
- water, including the marine environment and water quantities
- soil, including erosion and land degradation
- biodiversity and ecosystem services
- hazardous substances
- noise and vibration
- plant safety
- energy use
- waste and residues
9 / 15
Human and labour rights2 (b)
- occupational health and safety
- child labour
- forced labour
- discrimination
- trade union freedoms
5 / 15
Community life2 (c)
- community life, including that of indigenous peoples
1 / 15
Yardstick for the policyAnnex X pt. 4
- International Bill of Human Rights
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
- ILO Tripartite Declaration of Principles
- OECD Due Diligence Guidance for Responsible Business Conduct
- OECD Guidance for Minerals from Conflict-Affected and High-Risk Areas
What is remarkable is what is not on the list: copper, manganese and aluminium are absent although they sit in every cell. Under Article 48(8) the Commission may amend it by delegated act in view of technological progress. Build the traceability system so that a fifth raw material does not become a new project.
Which chemistries contain which of the four is covered in Battery chemistries at a glance - an LFP cell, for instance, manages without cobalt and nickel.
06 · Evidence
What to request from your suppliers
Article 49(2) is unusually precise about the documents that have to carry the chain of custody. These six items are the real work - and almost all of them come from outside the company.
| Point | Item | What exactly | Source |
|---|---|---|---|
| a | Description of the raw material | Trade name and type of the material | Own bill of materials, confirmed by the supplier |
| b | Supplier | Name and address of the supplier that supplied the raw material | Procurement, master data |
| c | Country of origin and transactions | From the extraction of the raw material to the immediate supplier | Supplier, queried across several tiers |
| d | Quantity in the product | Share of the raw material present in the battery, in percentage or weight | Cell manufacturer, material data sheet |
| e | Verification reports on suppliers | Third-party verification reports issued by a notified body | Supplier, to be passed on to downstream operators |
| f | Conflict-affected and high-risk areas | Where those reports are missing, additional information per the OECD guidance: mine of origin, places of consolidation, trading and processing, and taxes, fees and royalties paid | Supplier, only where relevant |
Point (c) is the hard one. Required is not only the country of origin but the chain of market transactions from the extraction of the raw material to the immediate supplier. Stopping at tier 1 does not satisfy it. Point (e) helps: a supplier's third-party verification reports have to be passed down the chain.
How to collect values, documents and responsibilities from suppliers is covered in What evidence does the battery passport require and on the page Suppliers and supplier data.
07 · Battery passport
Why the report shows up in the public passport
The point most overviews leave out: due diligence does not end at the authority. Part of its outcome becomes visible to anyone who scans the QR code.
Annex XIII point 1(d) lists, among the publicly accessible information relating to the battery model, the "information on responsible sourcing as indicated in the report on battery due diligence policy referred to in Article 52(3)". The public layer of the passport therefore points at the public annual report, not at the verification file. Article 52 distinguishes four audiences:
| Who sees it | What | How | Reference |
|---|---|---|---|
| The public | Annual report on the battery due diligence policy | On the internet, permanently retrievable | Art. 52(3) |
| The public, through the passport | Responsible-sourcing information taken from that report | Battery passport, public layer | Annex XIII pt. 1(d) |
| Market surveillance and national authorities | Verification report, approval decision, audit reports, evidence of a recognised scheme | On request | Art. 52(1) |
| Immediate downstream purchasers | All relevant information gained under the due diligence policy | Directly, with regard for business confidentiality | Art. 52(2) |
Six months where the field exists but the duty does not
The battery passport is mandatory from 18 Feb 2027, due diligence only from 18 Aug 2027. In between lies half a year in which a passport carries a field for responsible sourcing whose basis - the Article 52(3) report - is not yet legally required of many operators. Leave the field traceably empty or state the status; do not invent a claim.
What else lands on the public layer, and who sees the other two access levels, is in Which data goes into the battery passport. The wider context is in EU Battery Regulation 2023/1542.
08 · In Batteriepasswerk
What our product covers here - and what it does not
Batteriepasswerk is battery passport software, not a due diligence system. What it delivers is the data side of the obligation: provenance, evidence, traceability.
Evidence and certificates in one place
Verification reports, approval decisions and supplier evidence sit as documents on the model, with expiry dates and reminders. When market surveillance asks, they are findable rather than scattered.
Art. 52(1)An audit trail over every change
Every change to a model or a passport hangs in a SHA-256 hash chain. Ten years of retention then means showing the record and that it has not moved since.
Art. 48(3)The passport field itself
Responsible-sourcing information is part of the public passport content under Annex XIII. A dedicated Annex X workflow for policy, risk plan and report is announced as an add-on and is currently in preparation.
Annex XIII pt. 1(d)What no software can do
The company writes the policy, the company assesses the risk, and a notified body performs the verification. No tool replaces those three steps, and no vendor can pre-empt an approval decision. What software can do is the evidence: the data, where it came from, and that it has not changed.
How the hash chain works is explained in Audit trail and data integrity in the battery passport. Whether any of this applies to you at all is answered by the eligibility check in five questions.
09 · FAQ
Frequently asked questions on due diligence
When do the battery due diligence obligations start to apply?
On 18 August 2027. Article 48(1) of Regulation (EU) 2023/1542 originally said 18 August 2025; Regulation (EU) 2025/1561 of 18 July 2025 moved that date by two years. Only the date of application moved, not the substance of the obligations. In the same amendment, the Commission guidelines required by Article 48(5) were re-dated to 26 July 2026.
Which companies do the supply chain due diligence rules bind?
Economic operators that place batteries on the Union market or put them into service. Article 47 exempts operators whose net turnover was below EUR 40 million in the financial year preceding the last financial year - but only if they are also not part of a group that exceeds that limit on a consolidated basis. A small subsidiary of a large group stays in scope. The battery passport obligation itself has no turnover threshold.
Which raw materials does Annex X cover?
Four: cobalt, natural graphite, lithium and nickel. Their chemical compounds count too, as far as they are necessary to manufacture the active materials of the battery. Other metals such as copper, manganese or aluminium are not listed. The Commission may amend the list by delegated act in view of scientific and technological progress, so it is not fixed forever.
Does the battery due diligence report have to be public?
Yes. Article 52(3) requires the report to be reviewed annually and made publicly available, explicitly including on the internet. It must clearly identify the batteries concerned, describe the steps taken under Articles 49 and 50, name findings of significant adverse impacts and summarise the third-party verification, including the name of the notified body. Business confidentiality may be respected.
Who verifies a company's battery due diligence policy?
A notified body. Article 48(2) requires the policy to be verified by one and then periodically audited. Article 51 sets out what the verification must cover and ends in two documents: a verification report and, where the policy conforms, an approval decision. The audit principles follow the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
How does due diligence connect to the battery passport?
Annex XIII point 1(d) lists the information on responsible sourcing indicated in the Article 52(3) report among the publicly accessible battery passport content. The passport therefore points at the outcome of the due diligence work. The verification report, the approval decision and the audit reports stay with market surveillance and national authorities, who receive them on request under Article 52(1).
Do the obligations apply to second-life batteries?
Not where the battery was already placed on the market before preparation for re-use, preparation for repurposing, repurposing or remanufacturing. Article 47 second paragraph takes that placing out of Chapter VII. The exemption attaches to the individual battery, not to the company: an operator that also places new batteries on the market still owes due diligence for those.
10 · Sources
Sources & further reading
EUR-Lex · Regulation (EU) 2023/1542, Chapter VII and Annex X
Articles 47 to 53 in full, the raw material and risk list of Annex X, and Annex XIII point 1(d)
EUR-Lex · Regulation (EU) 2025/1561
The amendment to Article 48: application from 18 Aug 2027, guidelines by 26 Jul 2026, with the recitals that explain why
European Commission · Batteries and accumulators
Topic page listing the guidelines, delegated and implementing acts published so far
European Commission · Omnibus IV
The proposal package of 21 May 2025 that produced the postponement and proposes the further simplifications
Helpdesk on Business & Human Rights · Due diligence FAQ
Practitioner questions and answers on the Batteries Regulation, published by GIZ on behalf of the German BMZ
Scope first, effort second
Due diligence or not - the answer hangs on five questions
The free eligibility check tells you whether your batteries need a passport from 2027 and whether the Annex X due diligence obligations apply on top - no sign-up, result as a PDF.