Governance Briefing — August 18, 2025
Economic operators placing rechargeable industrial and EV batteries on the EU market must activate mandatory supply-chain due diligence programmes covering raw materials sourcing, risk mitigation, and audit reporting under the new Battery Regulation.
Executive briefing: Article 48 of Regulation (EU) 2023/1542 requires companies placing rechargeable industrial or electric-vehicle batteries above 2 kWh on the EU market to operate a due diligence policy from August 18, 2025. Programmes must surface social and environmental risks across raw material sourcing, ensure grievance handling, and publish mitigation results for cobalt, lithium, nickel, and graphite supply chains.
Key compliance checkpoints
- Policy adoption. Establish a governance-approved due diligence policy covering risk identification, mitigation, and third-party engagement aligned with OECD guidance.
- Risk assessment cadence. Conduct recurring supply chain risk mapping and integrate mining, refining, and recycling partners into enhanced monitoring.
- Public reporting. Publish annual sustainability reports that summarise identified risks, mitigation actions, and effectiveness metrics accessible via corporate websites.
Control alignment
- OECD Due Diligence Guidance. Map Battery Regulation requirements to the five-step framework, documenting grievance procedures and risk mitigation triggers.
- ISO 14001 and 45001. Integrate environmental and occupational safety management controls into supplier audits to demonstrate ongoing conformance.
- ESRS E3. Update sustainability reporting workstreams so CSRD-aligned disclosures capture battery-specific due diligence indicators.
Implementation priorities
- Deploy traceability platforms that consolidate sourcing attestations, smelter audit certificates, and grievance investigations for regulated materials.
- Set contract clauses requiring suppliers to share corrective action plans and remediation updates that satisfy Article 49 monitoring expectations.
Enablement moves
- Train procurement, sustainability, and legal teams on the Battery Regulation annexes so risk scoring and escalation thresholds are applied consistently across regions.
- Prepare board briefings outlining capital and operational impacts of due diligence, including alignment with voluntary initiatives such as the Global Battery Alliance.
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries (July 12, 2023)
- European Commission Q&A: New EU Battery Regulation (July 2023)
Zeph Tech operationalises EU battery due diligence through supplier risk mapping, traceability data integration, and governance reporting that evidences Article 48 compliance.