Compliance Briefing — September 20, 2025

Executive briefing: Regulation (EU) 2023/1542 on batteries and waste batteries has applied due diligence obligations since August 18, 2025 for economic operators placing rechargeable industrial batteries and electric vehicle batteries on the EU market. Articles 48 to 59 require supply-chain policies aligned with OECD guidance, identification and mitigation of social and environmental risks in the extraction, processing, and trading of cobalt, lithium, nickel, natural graphite, and chemical precursors, plus public reporting and third-party verification every three years. September production runs must therefore demonstrate documented risk assessments, supplier engagement, and corrective action logs.

Key compliance checkpoints

Policy publication. Adopt and disclose due diligence policies covering responsible sourcing, grievance channels, and alignment with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
Risk mapping. Maintain current maps of upstream and midstream operators, identifying high-risk regions, conflict zones, and labour-rights exposure across relevant battery materials.
Verification planning. Engage independent third-party verifiers to audit due diligence systems within 12 months, as required by Article 55.

Operational priorities

Supplier remediation. Track corrective actions for identified adverse impacts, documenting timelines, responsible parties, and closure evidence.
Reporting readiness. Compile data for the mandatory annual public report describing risk findings, mitigation steps, and engagement outcomes.
Contract integration. Update supplier agreements to mandate transparency, traceability data sharing, and adherence to grievance procedures.

Enablement moves

Deploy traceability platforms capable of ingesting smelter/refiner data, audit certificates, and site-level risk scores.
Coordinate with ESG teams to align battery due diligence disclosures with CSRD and supply chain transparency reporting.

Sources

Zeph Tech visualizes battery-material supply chains, schedules verifier engagements, and automates Battery Regulation due diligence reporting.