Compliance Briefing — August 5, 2025
EU Battery Regulation due diligence duties start on 18 August 2025, leaving cobalt, lithium, and nickel supply chains days to evidence responsible sourcing programs before national authorities begin inspections.
Executive briefing: Regulation (EU) 2023/1542 requires battery manufacturers and importers to implement supply chain due diligence systems by 18 August 2025. Obligations include establishing risk management policies aligned with OECD guidelines, verifying raw material provenance, and publicly reporting mitigation measures for social and environmental risks in cobalt, natural graphite, lithium, nickel, and manganese supply chains.
Key compliance checkpoints
- Chain-of-custody documentation. Collect supplier declarations, audit reports, and smelter/refiner identifiers covering the “exposure” minerals listed in Annex X, ensuring traceability back to extraction or recycling facilities.
- Risk assessment cadence. Run annual risk assessments that score suppliers on child labour, biodiversity harm, and corruption indicators while tracking mitigation progress in line with Article 48.
- Public reporting controls. Draft a 2025 due diligence report describing governance structures, identified risks, and remediation outcomes, ready for publication within 12 months of the financial year-end.
Operational priorities
- Corrective action playbooks. Define escalation thresholds for suspending or disengaging from suppliers when severe adverse impacts persist, and document stakeholder consultation per Annex XI.
- Third-party assurance. Engage accredited auditors to review due diligence systems and sampling programs, especially for high-risk mining jurisdictions.
- Customs alignment. Synchronize import declarations with due diligence records so customs authorities can verify compliance during checks initiated under Article 88.
Enablement moves
- Deploy supplier portals that capture policy attestations, grievance procedures, and mitigation updates with immutable timestamps.
- Map due diligence reporting outputs into CSRD and battery passport disclosures to reduce redundant data collection.
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- European Commission Battery Regulation FAQ
Zeph Tech operationalizes EU Battery Regulation controls with supplier risk dashboards, audit evidence vaults, and CSRD-ready reporting packs.
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