Battery
Battery Supply Chain Due Diligence and the Passport
Battery supply chain due diligence under Articles 48–52: four pillars for cobalt, graphite, lithium and nickel, the 2027 delay and the report in the passport
When supply chain due diligence comes up, most people think of the CSDDD. Yet the EU Battery Regulation (EU) 2023/1542 carries an older and more concrete regime: Articles 48 to 52 require a policy, risk management, independent verification and public reporting for four raw materials. What ties it to the battery passport is that the report itself becomes part of the passport.
This article explains what the duty asks for, what the 2025 postponement changed, and how a Turkish integrator using imported cells should structure it.
What is required
| Pillar | Obligation | Evidence |
|---|---|---|
| Policy | A written due diligence policy aligned with OECD guidance; reflected in supplier contracts; a senior manager responsible | Policy document, contract clauses, organisation chart |
| Risk management | Mapping the supply chain; identifying and mitigating the Annex X risk categories (environment, human rights, occupational health, communities) | Chain map, risk assessment, mitigation plan |
| Third-party verification | Verification of the policy and its implementation by a notified body | Verification report |
| Reporting | Annual review and a publicly available report | Published report; the copy in the passport |
The regime aligns with the OECD five-step due diligence framework for mineral supply chains from conflict-affected and high-risk areas: establish a management system, identify and assess risk, design and implement a response, commission an independent audit, report annually. The Commission may also recognise industry due diligence schemes; joining a recognised scheme makes the work easier but does not remove responsibility. The duty is not one-off: the policy and risk assessment are reviewed at least annually and refreshed when a supplier changes.
The postponement and the threshold
The regulation's original text applied the duty to economic operators with an annual net turnover above EUR 40 million, with Commission guidelines to be published before application. When the guidelines were late, Regulation (EU) 2025/1561 postponed application to 18 August 2027. The postponement does not touch the passport's 18 February 2027 date; only the due diligence field is filled later.
Staying under the threshold does not zero the burden: an in-scope importer or OEM needs the same data to write its own report, and the request travels downstream as described in tier-2 and tier-3 supplier transparency.
Where the report sits in the passport
Annex XIII lists the due diligence report among the passport's data fields; the passport must exist on 18 February 2027, while this field is filled at the latest by August 2028. The report is public, but the supplier list, refiner audit results and risk assessment behind it are competitively sensitive. Open those in restricted data tiers to authorised roles; for the role design see access roles in the battery passport.
A model for a Turkish integrator
The typical scenario: cells are imported from Asia, the pack is built in Türkiye, the product is placed on the market through an EU importer. The responsible operator in the regulation's eyes is the importer (see which batteries, who is responsible); but only the cell supplier knows where the cobalt, nickel, lithium and graphite inside the cell came from. The practical structure:
- From the cell supplier: the refiner list for cathode and anode active materials per cell model, the audit status of those refiners (programmes such as the Responsible Minerals Initiative) and the supplier's own due diligence report.
- Contract: data delivery, audit rights, notification when a refiner changes; for the clauses see DPP clauses for supplier contracts.
- Map: keep the CAM, pCAM and refiner tiers beyond the cell maker in a single supplier master record; the approach in supply chain traceability applies unchanged. The refiner tier is often unknown even to the cell maker; log the gaps in the first round and close them in the next.
- One dataset: CSDDD and CSRD/ESRS requests ask for the same map; build one source for all three reports.
- Publication: the report in the passport, the evidence in the restricted tier; every version in the audit trail.
Even though the importer is the responsible operator, your EU customer will expect this structure from you; a ready supplier gets preferred. For the scope and timetable summary see the battery passport guide; for the Türkiye-specific roadmap see the battery passport for Turkish manufacturers.
Frequently asked questions
When does battery due diligence start?
Regulation (EU) 2025/1561 postponed it to 18 August 2027. The deadline for the due diligence report to appear in the passport is August 2028.
Which raw materials does battery due diligence cover?
Cobalt, natural graphite, lithium and nickel, together with their compounds; the risk categories are listed in Annex X and aligned with OECD guidance.
I am a small manufacturer; does battery due diligence apply to me?
Below the turnover threshold you are not directly obliged; but your in-scope importer and OEM customers will ask you for the same data. The final threshold has not yet been confirmed.
