Beyond technical data, the regulation imposes supply-chain due-diligence obligations on economic operators that place batteries on the EU market above a turnover threshold. The aim is to manage social and environmental risks in the sourcing of raw materials.
Raw materials in scope
- Cobalt
- Natural graphite
- Lithium
- Nickel
- Chemical compounds based on these materials present in the active battery materials.
What the policy must do
| Step | Requirement |
|---|---|
| Management system | Adopt and communicate a due-diligence policy for the supply chain. |
| Risk identification | Identify and assess social and environmental risks in sourcing. |
| Risk mitigation | Implement a strategy to respond to identified risks. |
| Verification | Have the policy verified by a notified third party. |
| Disclosure | Report on the policy and make it available through the passport. |
The due-diligence report is a passport attribute. A summary is public; the detailed records sit in the authority tier for market-surveillance access.
For importers, this obligation cannot be fully delegated upstream. You may rely on supplier data, but you remain the operator responsible for the policy and its verification.
Frequently asked
Which raw materials does battery due diligence cover?
Cobalt, natural graphite, lithium and nickel, and the chemical compounds based on them in the active materials.
Does due diligence apply to small operators?
The obligation is tied to a net-turnover threshold, so the smallest operators may be exempt, but the data still has to exist in the passport where it applies.